Ten categories, twenty-eight product types
Which fields a passport needs, per product
A schema here is a field list: what a passport for that product type has to carry, what it should carry, and where each requirement comes from. Every type has three of them — required, recommended, and the full set.
The field list is the easy half. The regulation behind it is the half that moves, and most of these product groups do not have a date yet. Each category below says which rule it answers to and how firm that rule is.
Required
What the regulation asks for. A required field left empty blocks publishing — the validator marks it red and the passport does not go live.
Recommended
Encouraged, not required. Leaving one out costs coverage and shows amber, but nothing stops you publishing without it.
The full set
Both lists, filled. Every field green is what a passport looks like when there is nothing left for anyone to ask about.
In force
Batteries
The only category here with a passport requirement already in law. The EU Batteries Regulation (EU) 2023/1542, Article 77, requires a battery passport from 18 February 2027.
It does not cover every battery
Article 77 applies to LMT batteries, industrial batteries above
2 kWh, and EV batteries. Portable batteries and SLI batteries
are outside it. The portable-battery schema in this
repository is a field list for a product that has no passport
obligation, and it was published without saying so.
| Product type | Passport required | Under |
|---|---|---|
| ev-battery | Yes, from 18 Feb 2027 | (EU) 2023/1542 Art. 77 |
| industrial-battery | Yes if above 2 kWh, from 18 Feb 2027 | (EU) 2023/1542 Art. 77 |
| portable-battery | No | Outside Art. 77 |
Awaiting a delegated act
Everything under ESPR
ESPR (EU) 2024/1781 has been in force since 18 July 2024, but it sets no product requirements by itself. Each product group gets those in a delegated act, and requirements normally apply around eighteen months after one is adopted. No delegated act has been adopted for any group below.
The Working Plan 2025–2030, adopted on 16 April 2025, gives an indicative order. Textiles is the first group named in it, indicatively 2027 — which puts application somewhere around 2028 or 2029. Every date in this section is indicative, and none of it is settled.
| Category | Product types | Status |
|---|---|---|
| iron-steel | crude-steel, semi-finished, flat-products, long-products, tubes-pipes | Furthest along. The Commission consulted on a draft between May and August 2026 and adoption is indicated for late 2026. |
| textiles | garment, footwear, accessory | Indicatively 2027, not adopted |
| aluminium | unwrought-aluminium, aluminium-bars-profiles, aluminium-plates-sheets, aluminium-tubes-pipes, aluminium-structures | Indicatively 2027, not adopted |
| tyres | passenger-tyre, truck-tyre, retreaded-tyre | Indicatively 2027, not adopted |
| furniture | furniture | Indicatively 2028, not adopted |
| mattress | mattress | In the Working Plan, no year indicated |
| electronics | ict-product, energy-related | In the Working Plan, no year indicated |
The category files for aluminium and iron-steel both say
"delegatedAct": "Expected 2025-Q4". They were written on
11 December 2024, that quarter passed without an act, and the current
indications are late 2026 for iron and steel and 2027 for aluminium.
A different regulation
Construction products
Construction products are not covered by ESPR. They fall under the Construction Products Regulation (EU) 2024/3110, in force since January 2025, which has its own passport provisions introduced per product family through delegated acts — again with roughly eighteen months before each applies. None has been adopted.
The category file lists construction under ESPR 2024/1781. That is the wrong regulation.
| Category | Product types | Under |
|---|---|---|
| construction | cement, concrete, insulation, structural-timber, windows-doors | CPR (EU) 2024/3110 |
A different regulation
Detergents and surfactants
The Detergents and Surfactants Regulation (EU) 2026/405 was published in the Official Journal on 2 March 2026 and entered into force on 22 March 2026. It replaces Regulation (EC) No 648/2004, which is repealed on 23 September 2029 — the same day the new rules apply.
From 23 September 2029, every detergent and every end-user surfactant placed on the EU market needs a digital product passport, reached through a data carrier on the label or packaging and referenced in an EU registry. The passport is designed to work with the ESPR framework rather than beside it.
There is no detergent schema in this repository
After batteries, this is the firmest passport date in EU law — a published regulation with a date, not a delegated act somebody is still drafting. It is also the only category on this page with a date and no field list behind it. That gap is ours, and it is named here rather than left for someone to discover.
| Date | What happens |
|---|---|
| 22 Mar 2026 | Regulation (EU) 2026/405 in force |
| 23 Sep 2029 | Passport, data carrier and registry entry required. (EC) No 648/2004 repealed |
| 23 Sep 2030 | End of the transitional window for products already on the market |
Not a regulation
CIRPASS
Everything above is law, or a delegated act under a law. CIRPASS is neither. It is an EU-funded project, and the difference matters enough to give it its own section rather than a row in a table.
The first CIRPASS ran to 2024 and produced cross-sector recommendations for what a passport should hold. CIRPASS-2 follows it, running from May 2024 to April 2027 under the Digital Europe Programme with 49 partners and thirteen pilots across textiles, electronics, tyres and construction products. In June 2026 it published a reference architecture for the EU passport system, recommending JSON-LD as the default exchange format and modular templates per product group.
Following it makes you compliant with nothing
No obligation attaches to CIRPASS and no authority checks it. What it buys you is that the delegated acts are being drafted alongside this work, so a catalogue built to CIRPASS is a catalogue that will need less rework when a real requirement lands.
The validator can grade a passport against it, which is where the difference shows up in numbers. CIRPASS asks for 21 fields and treats all of them as mandatory. The ESPR base asks for 44 and marks 28 of those optional. The same passport therefore scores quite differently depending on which one you hold it against, and neither score is the other one being generous.
Using them
What a schema will and will not do
It tells you what to collect
Three sets per product type. The required set is what the regulation asks for, the recommended set is what makes a passport worth reading, and the full set is both.
It does not hold anything
A schema is a list of field names. The passports, the values, the inheritance between an item and its batch, and the versioning all live in DPP Agent.