The Intelligence Hub for Digital Product Passport & Compliance

Clear, practical guidance on circularity, sustainability regulations, and the software powering the transition—for businesses.

Covering the regulations and frameworks shaping the future of products:

ESPR
Digital Product Passport
Battery Regulation
Textiles Strategy
LCA
Traceability
PLM
EPR

Where Regulation Meets Practical Action

The regulatory landscape for products is shifting fast. ESPR, Digital Product Passports, and sector-specific rules are no longer future concepts—they are active compliance requirements with fixed deadlines. Circular Notes cuts through the complexity.

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Regulatory Clarity

Plain-English breakdowns of ESPR, DPP, and sector-specific obligations.

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Software Intelligence

Independent comparisons and buyer’s guides for DPP, LCA, and PLM platforms.

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Actionable Resources

Checklists, templates, and frameworks you can use today.

Regulatory timeline

The deadlines shaping product compliance, 2024–2040

From the Digital Product Passport to packaging, batteries and deforestation, these are the dates that decide what you must have ready, and when.

Today
2024
18 Jul 2024ESPR · DPP

ESPR comes into force

The Ecodesign for Sustainable Products Regulation becomes law, creating the legal basis for ecodesign rules and the Digital Product Passport across almost all physical goods.

2025
11 Feb 2025PPWR

Packaging regulation adopted

The Packaging and Packaging Waste Regulation enters into force, starting an 18-month countdown before its rules apply.

April 2025ESPR · DPP

First product groups named

The 2025–2030 ESPR working plan sets the first priorities, including textiles, furniture, tyres, mattresses, steel and aluminium. Work on detailed passport requirements begins.

2026
19 Jul 2026ESPR · DPP

EU passport registry due

The Commission’s central registry, which will store the unique identifiers linked to every Digital Product Passport, is due to be in place.

19 Jul 2026ESPR

No more destroying unsold clothing

Large companies can no longer destroy unsold apparel and footwear, and must disclose what they discard and why.

12 Aug 2026PPWR

Packaging rules start to apply

The general application date of the PPWR. Obligations then phase in over the following years.

27 Sep 2026Green claims

Stricter rules on green claims

The Empowering Consumers for the Green Transition Directive applies: vague environmental claims and offset-based “climate neutral” product claims are banned unless they can be proven.

30 Dec 2026EUDR

Deforestation rules for larger firms

Large and medium-sized operators, and traders, must show that covered products such as cattle, cocoa, coffee, palm oil, rubber, soy and wood are deforestation-free.

2027
18 Feb 2027Batteries

Digital Battery Passport required

Every EV battery, light-means-of-transport battery and industrial battery above 2 kWh placed on the EU market needs a passport. It is the first mandatory product passport in EU law.

30 Jun 2027EUDR

Deforestation rules for small firms

Micro and small operators are brought into scope for the remaining covered products.

2027–2028ESPR · DPP

First ESPR product passports

Passports are expected for the first priority groups, such as textiles and clothing, furniture, steel and aluminium, as each delegated act is adopted. Timing is indicative.

2028
From 12 Aug 2028PPWR

One labelling system for packaging

Harmonised labels tell consumers how to sort each piece of packaging. The date can move later, depending on when the implementing acts are adopted.

2030
1 Jan 2030PPWR

Recyclable packaging becomes the rule

  • All packaging must meet design-for-recycling grade A, B or C.
  • Plastic packaging needs a minimum share of recycled content, between 10% and 35% depending on the type.
  • Empty space in grouped, transport and e-commerce packaging is capped at 50%.
2035
2035PPWR

Recyclable in practice, not just on paper

Packaging must be “recycled at scale”: actually collected, sorted and recycled across the EU, not only recyclable in theory.

2038
2038PPWR

Only the best-performing packaging

Grade C packaging is phased out. Only packaging rated A or B for recyclability can be placed on the market.

2040
2040PPWR

Higher recycled-content targets

Minimum recycled content in plastic packaging rises again, to between 25% and 65% depending on the type, as circularity targets tighten.

Dates reflect adopted EU legislation as of September 2026. Some depend on delegated or implementing acts and may move. Read our analysis →

Our Expertise

Focused research where regulation meets product data

Circular Notes focuses on four connected areas. We read the primary texts, follow them as they change, and turn them into guidance that product, compliance and sustainability teams can act on.

How we work

  • 1Primary sources firstWe work from the regulations and delegated acts themselves, not press releases.
  • 2Plain English, practical stepsEvery note ends with what it means for your products and teams.
  • 3IndependentNo ties to software vendors, so our comparisons stay honest.
  • 4Open about what’s unsettledWe say when a rule is still moving, and date any correction at the top.
01

ESPR

Ecodesign for Sustainable Products Regulation

We follow the regulation, its delegated acts and the consultation responses, and translate them into what changes for your products, and when.

  • Timelines and priority product groups
  • Delegated acts and information requirements
  • Duties for manufacturers, importers and distributors
02

DPP

Digital Product Passport

What a passport has to contain, who can see which data, and how to structure the information behind it so it holds up.

  • Data requirements and access rights
  • Identifiers, data carriers and the EU registry
  • Data architecture and system integration
03

Traceability

Supply chains you can prove

Mapping where materials and components come from, and collecting supplier data that can actually be verified.

  • Supply-chain mapping beyond tier 1
  • Collecting and checking supplier data
  • Material provenance and battery passports
04

Sustainability

The wider circular shift

Design for durability, repair and recovery, and environmental claims that stand up to the new consumer rules.

  • Circular design and end-of-life
  • Life cycle assessment (LCA) basics
  • Green claims and consumer protection rules

Prepare for ESPR with Confidence

Subscribe to Circular Notes for plain-English updates on ESPR, the Digital Product Passport and the rules reshaping how products are made, tracked and recovered.

What you’ll get:

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Illustrated avatar of Arden Hale

Arden Hale

Independent writer & researcher

About Circular Notes

Circular Notes is an independent publication founded by Arden Hale, an independent writer and researcher focused on EU product regulation.

Our mission is simple: to help businesses across the UK, EU, and beyond navigate the complex shift toward circular, compliant, and transparent products.

We are not affiliated with any software vendor. Our analysis is independent, our guides are practical, and our focus is always on helping you take action.