Regulatory · changelog

Regulatory changelog — what we tracked, what we changed

Every regulatory event we track that touches a Digital Product Passport schema, paired with the action we took (or deliberately didn't take). The companion to the matrix pages — those show what we model today; this shows how we got here.

Status

Schema-bumped
We changed something in response — added fields, changed an enum, bumped a template version.
Monitoring
Tracking the event; no schema change is needed yet, or the change hasn't landed.
Pending review
Noted, full impact assessment ongoing — likely to graduate to monitoring or schema-bumped.
No impact
Observed, not relevant to current schemas — kept here for the audit trail.

Watching for

Battery DPP becomes mandatory — 18 February 2027
Tyres ESPR delegated act and horizontal electronics measures on repairability and recycled content — not adopted, no passport date yet
Furniture ESPR delegated act — expected 2029-2030
Carbon-footprint acts under Battery Reg Article 7 — delegated act on the calculation methodology, implementing act on the declaration format

27 May 2026 · EU · Battery Regulation · ESPR

Commission battery-passport webinar — indicative roadmap, corrigendum 2026/90285, draft EN 18219/18220 move, Omnibus IV proposal

Monitoring

DG GROW's 27 May 2026 webinar presented an indicative DPP roadmap — a planning view, not law: DPP Registry operational July 2026, battery passport mandatory 18 February 2027, then ESPR delegated acts for iron & steel (Q4 2026) and textiles/aluminium/tyres (2027), with DPP dates shown for packaging/iron & steel/construction (2028), ICT/tyres/aluminium/textiles/detergents (2029) and toys (2030). Of those dates, only batteries (18 February 2027), detergents (23 September 2029, Regulation (EU) 2026/405) and toys (1 August 2030, Regulation (EU) 2025/2509) are fixed in law: the ESPR groups wait on delegated acts, construction on a delegated act under the CPR, and packaging gets no passport under the PPWR. Three items to track: corrigendum 2026/90285 (10 Apr 2026) corrects Battery Reg Annex XIII point 1(q) marking reference from Article 13(3)+(4) to 13(4)+(5); the webinar announced a delegated act moving the QR/unique-identifier standards to EN 18219 + EN 18220 — a draft, not law: until it is adopted, Article 77(3) names the ISO/IEC 15459 series; and it presented an Annex XIII point (t), printable instructions for stationary battery energy storage systems, from the Omnibus IV proposal (COM(2025) 504). That proposal has not been adopted, so Annex XIII point 1 still ends at (s). Omnibus IV is not Regulation (EU) 2025/1561, a separate act that amends only Article 48 and moves the due-diligence obligations to 18 August 2027.

Impact

No schema change today. The corrigendum's marking reference (13(4)+(5)) and the EN 18219/18220 carrier-standard move are tracked against the battery template; we update field references if and when the delegated act is adopted. Three roadmap dates are statutory — batteries 18 Feb 2027, detergents 23 Sep 2029, toys 1 Aug 2030; the other roadmap dates are indicative.

Links

30 April 2026 · TracePass · ESPR · GS1 Digital Link

Enum localisation across all templates (24 EU locales)

Schema-bumped

Machine-readable enum values across all 12 product-category templates now carry localised labels in 24 EU languages. The display layer resolves the consumer's locale to the right label; the underlying enum keys are unchanged so passports created before this change continue to validate.

Impact

No schema-key change. Label additions only. No migration required for in-flight passports.

15 April 2026 · TracePass · ESPR · Templates

Per-category templates v1 — jewellery, chemicals, furniture, tyres, electronics

Schema-bumped

Five new templates published (jewellery 52 fields, chemicals 96, furniture 80, tyres 95, electronics 166). Each is speculative-but-anchored against companion regulations: REACH + CLP for chemicals, Tyre Labelling 2020/740 for tyres, Ecodesign + EPREL for electronics, EN durability standards + FSC for furniture, RJC + OECD + Kimberley for jewellery.

Impact

Net new templates. Existing battery and textile templates unchanged. Schema-bump per template version.

Battery carbon-footprint methodology — delegated-act drafts in flight

Pending review

The Joint Research Centre and the European Commission continue to refine the carbon-footprint calculation rules and performance-class boundaries under Article 7 of Regulation (EU) 2023/1542. The methodology and the performance classes are set by delegated acts (Art. 7(1) and 7(2), fourth subparagraph, point (a)); the format of the declaration is set by an implementing act (Art. 7(1), fourth subparagraph, point (b)). Together they fix how values are declared for electric-vehicle, light-means-of-transport (LMT), and rechargeable industrial batteries above 2 kWh.

Impact

Pending review. The battery template's CF fields are already in place; values declared against an older methodology stay valid until the customer republishes. We expect to bump the schema only if new fields are introduced — not for value-recalculation only.

ESPR (EU) 2024/1781 entered into force

Monitoring

The Ecodesign for Sustainable Products Regulation (ESPR) entered into force, establishing the framework for ecodesign requirements across product categories. The regulation does not create per-category obligations directly — those will come through delegated acts on per-category timelines, which TracePass tracks separately.

Impact

Monitoring. Templates v1 followed in April 2026 — speculative-but-anchored coverage for the five categories most likely to receive early delegated acts.

Links

17 August 2023 · Battery Regulation · Framework

Battery Regulation (EU) 2023/1542 entered into force

Schema-bumped

The foundational regulation for the EU Battery Passport. Articles 7, 8, 11, 14, and 77 establish the core data points for industrial, electric-vehicle, and light-means-of-transport batteries. The Battery Passport itself becomes mandatory on 18 February 2027 under Article 77.

Impact

Battery template created in response. The article-by-article coverage is documented separately on the Battery Reg matrix page.

Links

Where this fits: see the buyer's guide

/buyers-guide →

Reviewed by Malin Ivanov, Managing Director — on 2026-05-27