Industries First Affected

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When, What, How?

The Digital Product Passport (DPP) is rolled out in phases on the ESPR delegated-act schedule (Working Plan 2025–2030, adopted 16 April 2025). The first sector is iron and steel (2026 delegated act), followed by aluminium and textiles (2027), and furniture (2028). Batteries are governed by a separate Battery Regulation. In Bulgaria this will hit producers, importers and traders in the steel and textile sectors first — they will set the standard for the rest of the categories on the Bulgarian and European market.

First with DPP

List of Affected Industries

Iron and steel

The first ESPR delegated act is adopted in 2026. After an 18-month grace period, companies must maintain DPPs with data on composition, recycled content, carbon footprint and production route (~2027–2028). Linked to the Industrial Accelerator Act: from 1 January 2029 public procurement for steel requires at least 25% low-carbon steel.

Aluminium

ESPR delegated act – 2027. Like steel: requirements for recycled content, carbon footprint and material origin. Under the Industrial Accelerator Act – from 1 January 2029 public procurement requires 25% low-carbon aluminium + Made-in-EU. For Bulgaria the sector matters because of exports to automotive and construction manufacturers in the EU. Aluminium is an energy-intensive industry, so being able to prove origin and carbon intensity will be a key competitive advantage in green public procurement.

Textiles and clothing

The textile delegated act is expected in 2027; DPP compliance itself starts ~2028–2029 (after the 18-month grace period). A separate, earlier measure: from 19 July 2026 large enterprises may not destroy unsold textiles and footwear. The revision of the Textile Labelling Regulation (TLR) is expected as a proposal in Q2 2026 – a mandatory digital label even outside the scope of the ESPR DPP.

Furniture

ESPR delegated act – 2028; DPP compliance starts ~2029–2030. Passports will contain data on material origin, repairability, recyclability and carbon footprint. A sector with a large volume of waste and low recyclability – critical for the circular economy. For Bulgarian furniture producers this is an opportunity to differentiate their products on the European market through proven sustainability, especially in the B2B segment (hotels, office fit-out, public sector).

Electronics

Electronics is in the Working Plan as a later-stage priority (through 2030). Expected DPP data: energy efficiency, repairability, component traceability, end-of-life waste-management information. The sector is particularly complex because of long supply chains – chips, PCBs and rare-earth elements often come from dozens of suppliers across regions. DPP will require manufacturers to keep transparency on composition and to provide access to spare parts for a minimum period after market placement.

Batteries (separate regulation)

Batteries are not under ESPR but under the Battery Regulation (EU) 2023/1542. The Battery Passport is mandatory from 18 February 2027 for all EV batteries, industrial batteries above 2 kWh, and light means of transport – the first real example of a digital passport in operation in the EU. The passport will contain data on chemical composition, carbon footprint, recycled raw-material share (lithium, cobalt, nickel), expected lifespan and reuse possibilities. This sets the standard for all subsequent ESPR DPP regimes – battery manufacturers will be the first to operationally test the registry and the technical infrastructure.

Construction products and materials

Construction products are not in ESPR but under the separate Construction Products Regulation (CPR). The delegated act for DPP service providers is expected in Q4 2026; the first product-group standards (cement and concrete) by the end of 2027. Mandatory DPP then phases in product-family by product-family, with an 18-month window. This is especially important for Bulgarian construction and EU exports – CBAM already requires proof of carbon footprint for steel, cement and aluminium imports, and DPP adds product-level traceability on top.

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Business and the New EU Rules: Time for DPP

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DPP

Frequently Asked Questions

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Batteries are first (from 2027), followed by textiles, electronics, and construction materials. This is key due to the high environmental footprint and the need for traceability.

They must ensure that every product has a valid passport, accessible to customers, partners, and regulators. This is a condition for placing products on the European market.

These sectors are associated with high emissions, difficult recyclability, and significant waste. DPP aims to reduce environmental impact and promote more sustainable production.

Information about composition, material origin, energy efficiency, carbon footprint, repairability, recyclability, and conditions for safe use.

It will provide transparency and traceability, facilitating collaboration, trust, and access to new markets in the EU.

Earlier compliance, avoiding sanctions, competitive advantage, greater customer trust, and the opportunity for financing through European programs.

Yes, other sectors will gradually be included, such as furniture, tires, mattresses, steel, aluminum, and materials with high energy consumption.

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