What changed in the regulations
A timeline read from the primary sources
TIMELINE
What changed in the regulations
A log of changes to ESPR and the Digital Product Passport, read from the primary sources. Newest first.Verified on 6 October 2026The Commission proposes moving the battery passport onto the DPP standards
The Commission has published a draft delegated regulation under the Batteries Regulation for feedback. It replaces the sentence in Article 77(3) that requires the battery passport's QR code and unique identifier to comply with the ISO/IEC 15459 series. The new text reads: the QR code shall comply with EN 18220:2026 and the unique identifier with EN 18219:2026, or their equivalent. These are the European standards for digital product passport data carriers and unique identifiers that were cited in the Official Journal on 15 July. In practice, the battery passport and ESPR passports are heading for the same technical basis for the identifier and the QR code. The same act also sets minimum performance and durability values for rechargeable industrial batteries above 2 kWh. This is a draft, not an adopted act. Feedback is open until 27 October 2026.Source: Draft Commission Delegated Regulation supplementing and amending Regulation (EU) 2023/1542, Ares(2026)9188325 — Article 2(1) and recital 10; Have your say, initiative 14460, feedback 29 September to 27 October 2026Batteries Regulation →The Empowering Consumers Directive applies from 27 September
From 27 September 2026 Member States must apply the measures transposing Directive (EU) 2024/825. The directive amends the Unfair Commercial Practices Directive and the Consumer Rights Directive. It does not amend the ESPR, and no product passport becomes mandatory on this date. Three things move onto the per-se blacklist in Annex I of Directive 2005/29/EC. Generic environmental claims — "eco-friendly", "green", "sustainable" — where the trader cannot demonstrate recognised excellent environmental performance relevant to the claim. Claims that a product has neutral, reduced or positive environmental impact on the strength of emissions offsetting. Sustainability labels that are not based on a certification scheme and were not established by public authorities. Until now these were judged case by case under the general misleading test. From 27 September they are unfair in themselves. The penalty figure is a floor on the ceiling, not a minimum fine. Where penalties are imposed under Article 21 of Regulation (EU) 2017/2394 for widespread infringements, Article 13(3) of Directive 2005/29/EC requires the maximum amount of the fine to be at least 4% of the trader's annual turnover in the Member State or Member States concerned. Where turnover figures are unavailable, Article 13(4) sets that maximum at no less than EUR 2 million. Member States may go higher, and enforcement is national. A directive binds Member States, not traders directly. Where a Member State has not transposed in time, the obligation that bites on 27 September is the State's own. On 28 May 2026 the Commission opened infringement procedures against 20 Member States for failing to communicate complete transposition. The same directive adds a disclosure duty that starts with the manufacturer. Where no EU reparability score exists for the goods, and today none exists for furniture or textiles, the trader must give information on the availability and estimated cost of spare parts and the procedure for ordering them, on the availability of repair and maintenance instructions, and on repair restrictions. That is Article 5(1)(j) of Directive 2011/83/EU, and Article 6(1)(v) for distance sales. The duty applies “provided that the producer makes the information available to the trader”. Without the manufacturer's data, the trader has nothing to show.Source: Directive (EU) 2024/825 of the European Parliament and of the Council of 28 February 2024, Article 4(1) — “They shall apply those measures from 27 September 2026”; Directive 2005/29/EC, Article 13(3) and (4) (consolidated text 02005L0029-20220528); Directive 2011/83/EU, Article 5(1)(j) and Article 6(1)(v), as amended by Directive (EU) 2024/825.Day one of the green-claims ban →The EU customs handling fee for distance-sales goods will be EUR 2 per item
The Commission has adopted a delegated regulation setting the Union handling fee under the new Union Customs Code, Regulation (EU) 2026/2108, at EUR 2 per item. The fee is due when goods sold at a distance are released for free circulation in the EU — mainly parcels sent by online sellers outside the Union to buyers inside it. The regulation enters into force on publication in the Official Journal and applies from the tenth day after. As of 6 October it has not been published. The fee creates no new digital product passport obligation. A passport becomes mandatory only through an act for the product group concerned, and no such act exists yet for textiles, furniture, iron and steel or construction products.Source: Commission Delegated Regulation C(2026) 6694 final of 21 September 2026 — Articles 1 and 2 (transmitted to the Council on 22 September, doc. 13480/26); Regulation (EU) 2026/2108, Articles 20(2) and 287(4)Digital Product Passport →The last two digital product passport standards are published — but not yet cited
CEN-CENELEC published EN 18239 (access rights management, information system security and business confidentiality) and EN 18246 (data authentication, reliability and integrity). These are the two standards left out of the decision published on 15 July, which cited the first six. The CEN-CENELEC register now lists both as “Published”, with a date of availability of 16 September 2026. Published is not the same as cited. The register's Official Journal field still reads “citation expected”, and the Commission's page on harmonised standards for the passport lists only the July decision. The Commission's own timeline places the decision on the remaining two standards in September 2026. Until that decision appears, neither standard gives a presumption of conformity. And these are the two that cover how a passport is protected: who may see which data, and how you prove the data is authentic and unaltered.Source: CEN-CENELEC register, CEN/CLC/JTC 24 — EN 18239:2026 and EN 18246:2026, status “Published”, date of availability 16 September 2026Harmonised standards →The Commission cites a harmonised standard for electric-vehicle batteries
By Implementing Decision (EU) 2026/2048 of 14 September, the Commission published in the Official Journal the reference of EN 18060:2025 as a harmonised standard under the Batteries Regulation. The standard covers the performance and durability of electric-vehicle battery modules and packs. The decision entered into force on publication, 16 September. From that date a battery that meets the standard benefits from a presumption of conformity, but only with the requirements of Regulation (EU) 2023/1542 that the standard actually covers. It is a standard about the battery itself, not about the technical design of its passport.Source: Commission Implementing Decision (EU) 2026/2048 of 14 September 2026, OJ L, 16 September 2026 — EN 18060:2025Batteries Regulation →Feedback opens on the Public Procurement Act — until 18 November
The Commission opened proposal COM(2026) 590 for feedback on its “Have your say” portal. The window runs eight weeks and closes on 18 November 2026. This is the proposal that lets a public buyer require the declaration of conformity through the digital product passport, and that amends the ESPR, the Batteries Regulation, the Construction Products Regulation and the Packaging Regulation. It is the window for comments from industry associations and manufacturers. As of 17 September the European Parliament has still not settled the committee responsible or appointed a rapporteur.Source: “Have your say” portal, initiative “Revision of EU rules on public procurement” — COM(2026) 590, published 15 September 2026, feedback until 18 November 2026Digital Product Passport →Bulgaria adopts its national rules for the CBAM registry
Bulgaria's Council of Ministers adopted an ordinance on the CBAM Registry and on decisions under the Carbon Border Adjustment Mechanism (Decree No 141 of 10 September 2026). It was published in the Bulgarian State Gazette No 85 on 15 September and entered into force the same day. The Executive Director of the Executive Environment Agency is the competent authority and administers the registry. The obligation itself is EU-wide; what the ordinance adds is Bulgaria's procedure. An importer of goods covered by Regulation (EU) 2023/956 — other than those exempted under its Article 2a — applies through the registry for authorised CBAM declarant status before importing, with a tax-clearance certificate, a sworn declaration, evidence of financial and operational capacity and a forecast of import volumes. The authority decides within 120 days, or 150 where it asks for more information. An importer from outside the EU acts through an indirect customs representative established in Bulgaria.Source: Bulgarian ordinance on the CBAM Registry, adopted by Council of Ministers Decree No 141 of 10 September 2026, State Gazette No 85 of 15 September 2026 — Articles 3, 5, 6 and 9CBAM →The digital product passport enters EU public procurement law
The Commission adopted a proposal for a Regulation on public contracts and concessions (COM(2026) 590 final, procedure 2026/0265(COD)), replacing the three 2014 procurement Directives with a single directly applicable Regulation. Article 92(1) lets a public buyer require that the declaration of conformity or of performance be provided “through the digital product passport pursuant to Regulation (EU) 2024/1781”. Article 28(4) adds that where the buyer applies the European-preference measures of Article 73(2), the country-of-origin declaration for the goods is incorporated, where applicable, into the passport itself. Annex VII lists the acts whose classes and thresholds become mandatory in green procurement: the Construction Products Regulation, the ESPR, the Batteries Regulation, the Packaging Regulation and the Net-Zero Industry Act. The difference worth noting: until now the passport was an instrument of compliance. Here it becomes a commercial one as well — a way to prove conformity to a public buyer. Article 147 deletes Article 65 of the ESPR and redirects that subject matter to the new Regulation. This is a proposal, not an adopted act, and the ordinary legislative procedure lies ahead. The file was registered with the Council on 10 September (doc. 12969/26); Parliament has not yet appointed a rapporteur.Source: Proposal for a Regulation on public contracts and concessions, COM(2026) 590 final, 9 September 2026 — Articles 28, 92, 147 and Annex VIIDigital Product Passport →A new European document on circular textiles was published — and it introduces no requirements
CEN published CEN/TS 18272-1 “Textiles – Circular economy for textile products – Part 1: General principles and guidance”, developed by technical committee CEN/TC 248, working group 39. In CEN's own words: rather than introducing new requirements, the Technical Specification provides a common reference point. The distinction matters and almost nobody in the market draws it. This is a Technical Specification, not a European Standard, and it is not cited in the Official Journal — so it carries no presumption of conformity and creates no obligation for anyone. The obligations will arrive with the next parts of the programme, now under development: circular design, non-virgin input materials, collection and sorting, and minimum durability requirements.Source: CEN-CENELEC, news posting of 26 August 2026; CEN/TC 248/WG 39Harmonised standards →The Commission revised its Registry User Guide — software certificates are now rejected
The guide for economic operators is now at version 1.02: 62 pages against 50 in the previous one. Almost the entire increase sits in the step where the declaration is signed. A qualified certificate installed as a software file (.p12 or .pfx) is now explicitly rejected — it produces only an advanced signature. Only a certificate held on a qualified signature creation device (a smart card or USB token from your provider), or a qualified remote signing service, will pass. The guide also names two free Commission validation tools: if the Qualification field reads QESig or QESeal, the signature passes; if it reads AdESig-QC, it will be rejected. Meanwhile the text still states, word for word, that it is not currently possible to successfully register a digital passport — the semantic catalogue for batteries has not yet been defined.Source: “DPP Registry User Guide for Economic Operators”, DG GROW Digital Solutions, version 1.02, published 24 August 2026, 62 pp.Digital Product Passport →The battery passport access-rights act missed its statutory deadline
The Batteries Regulation requires the Commission to set out in a separate act who may see which passport data — the manufacturer, the market surveillance authority, the purchaser, whoever will recycle the battery. The deadline written into the regulation itself was 18 August 2026. The act has not been adopted; the Commission's indicative timeline now points to the last quarter of 2026. The 18 February 2027 obligation does not depend on that act and is not being postponed. The regime begins with access tiers that are both legally required and operationally undefined.Source: Regulation (EU) 2023/1542, Article 77(9)Batteries Regulation →The Commission published the full field list for the battery passport
Version 2.0 of the DG GROW guidance lists 71 data points and states for each whether it is mandatory, conditional or optional — separately for the three battery categories. The count produces a surprise: an e-bike battery carries 50 mandatory fields, against 47 for an electric car and 32 for an industrial battery. The last twenty-one fields (51 to 71) are dynamic — state of health, charging cycles, power fade, and explicitly "negative events, such as accidents". The passport is therefore a record maintained across the battery's life, not a document filed once. The document states expressly that it does not represent the Commission's official position. Several fields still carry a note that the format is yet to be determined.Source: Guidance Document: Digital Batteries Passport — data points by category, version 2.0, 15 August 2026, DG GROWTraceability →New limits on lead and hexavalent chromium in batteries entered into force
Regulation (EU) 2026/1738 replaced the substance-restriction table in Annex I of the Batteries Regulation in full, adding limit values for lead and hexavalent chromium in traction and starter batteries in cars and light commercial vehicles. A distinction worth drawing: this changes composition requirements, not the passport. Lead-acid starter batteries remain outside the scope of the digital passport.Source: Regulation (EU) 2026/1738, Article 53 and Annex XIIBatteries Regulation →The iron and steel act consultation has closed
The public consultation on the first ESPR product delegated act — for iron and steel — opened on 20 May and closed on 12 August 2026. The Commission is processing the feedback; the scope covers carbon footprint, recycled content and the data the passport will disclose. The indicative adoption timeline remains Q4 2026. Steel is the first ESPR group — the act that emerges from this consultation will set the template every other sector's act is written against.Source: European Commission public consultation, 20 May – 12 August 2026DPP for steel and iron →The Commission's Digital Product Passport Registry went live
The system every passport must be recorded in is in real operation — together with a testing environment and user guidelines. Registration runs through a secure interface or an application programming interface, and economic operators may request proof of registration as a secure electronic document. The practical consequence is that the infrastructure is no longer in preparation. It exists, and it is waiting for content.Source: Commission Implementing Regulation (EU) 2026/1778, adopted 16 July 2026, published in the Official Journal on 17 July 2026Digital Product Passport →The six digital passport standards were cited in the Official Journal
With Implementing Decision (EU) 2026/1736 the Commission published in the Official Journal the references of EN 18216, EN 18219, EN 18220, EN 18221, EN 18222 and EN 18223 as harmonised standards under the ESPR. From the date of publication, a digital passport built to them benefits from a presumption of conformity with Articles 10 and 11 of the regulation — the legal step that the publication of the standards on 27 May did not by itself provide. The standards are horizontal: they define how the passport works technically, but create no obligation for any product. The two security standards — on access rights and on data authenticity — were not cited and remain in draft.Source: Commission Implementing Decision (EU) 2026/1736, adopted 14 July 2026, published in the Official Journal on 15 July 2026; the presumption follows from ESPR Article 41(2)Harmonised standards →The six core European standards for the digital passport were published
CEN and CENELEC published EN 18216, EN 18219, EN 18220, EN 18221, EN 18222 and EN 18223 — the horizontal standards defining how the passport is identified, carried, transported and exchanged. They were developed by the joint technical committee JTC 24. Publishing a standard is not the same as presumption of conformity. That follows only once the Commission cites the standards in the Official Journal — which, for these six, happened on 15 July 2026 (see the entry for that date). The two security standards — on access rights and on data authenticity — are still in draft.Source: CEN-CENELEC, date of availability 27 May 2026; presumption of conformity follows from ESPR Article 41Harmonised standards →
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