What matters under ESPR in 2026?
2026 is the year in which ESPR moves from strategy into implementation. On 9 February 2026, the European Commission adopted delegated and implementing acts for the ban on destroying unsold apparel, clothing accessories and footwear.
The key distinction is between framework law and concrete obligation: ESPR is already in force, but a product passport becomes mandatory for individual product groups only when the relevant delegated act defines requirements, data fields and transition periods.
Which product groups come first?
The ESPR Working Plan 2025-2030 prioritises product groups with high environmental impact and circularity potential. These include iron and steel, aluminium, textiles and apparel, furniture, tyres and mattresses.
This order is not the final legal date for every product, but it is a strong planning signal. Companies selling in these groups should not wait to map master data, material evidence, supplier information and environmental metrics.
- Metals: iron, steel and aluminium as upstream key materials.
- Consumer products: textiles, apparel, furniture, tyres and mattresses.
- Horizontal measures: repairability, recyclability and recycled content for electrical and electronic products.
What happens in 2027?
2027 matters because the battery passport becomes mandatory from 18 February 2027 for LMT batteries, industrial batteries above 2 kWh and electric vehicle batteries. That duty comes from the EU Battery Regulation, not from an ESPR delegated act.
At the same time, ESPR implementation for first priority product groups will become more concrete. The operational pattern is similar: unique identification, QR code or data carrier, machine-readable data, access rights and auditable freshness.
How should companies plan for 2028-2030?
From 2028 to 2030, ESPR will be translated into more product group rules. Companies should prepare more than a single pilot SKU and build a repeatable data model for product families, variants, suppliers and evidence.
The most important decision is organisational: who owns which data, who may change it, how each change is approved and how the passport remains available throughout the product lifetime. Without that governance, publication becomes fragile.
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