Two clocks running simultaneously
There is no countdown to a single fixed date. Two clocks are running simultaneously: the Brussels clock, which determines when the requirement enters into force legally, and the clock of your own company, which determines how much time you need to prepare for it. The question "how long does it take" therefore has two answers, and the second is usually the answer that matters in practice.
For the first clock: the regulation itself works with delegated acts per product group. For iron and steel, the ESPR work plan states that the first delegated act is expected in 2026, and that the requirements then enter into force eighteen months later. This amounts to an expected period around 2028, but that date is not yet fixed. Once the act is published, the deadline is official and no longer an expectation.
What is precisely fixed, and what is not
The eighteen months following publication of the delegated act is a deadline provided for in this phase of the ESPR policy process; it is not a deadline that varies per company. What may differ per product group is the content of the act itself: which data is made mandatory, and for which categories of steel and iron. This article deliberately makes no prediction on this. For the current state of affairs, you look at the published text on EUR-Lex or at the announcements from the European Commission; we keep track of that and incorporate it into the knowledge base with explanations per subject.
The second clock, that of your own company, is less clear-cut to formulate because it depends on your position in the supply chain and on how your data is already documented. A manufacturer that already keeps material certificates digitally and in structured form has a shorter path ahead than a company where the same data is still scattered in loose PDFs and emails.
Where the processing time gets stuck in practice
Companies preparing for this usually do not run into problems with the law itself, but with three practical points. The first is gathering data from suppliers who are not yet ready themselves; a passport is only complete if the origin and composition of the material are correct, and that requires cooperation further down the supply chain. The second is coordination with the software supplier or ERP system: who will supply the data going forward, in what format, and who will manage the connection. The third is the time needed to adapt contracts with suppliers and customers, so it is clear who supplies and maintains which data.
None of these three points is something you sort out in a few days, even if the legal requirement has not yet entered into force. Anyone who waits until the delegated act is published will only then start to figure out internally what is needed, whereas that time could be better spent on actually preparing data and systems.
What you can do now, without the date being fixed
Because the exact entry into force date is not yet fixed, it is difficult to make a project plan with firm deadlines. However, it is possible to map out now where you stand in the supply chain, which data you already have and which is still missing. With a few questions you can see roughly where you stand, without having to wait first for the final regulations. If you wonder how we get our information and why it provides direction without being a promise, you can read that on the page that explains where our information comes from.
The ultimate assessment of what this means for your specific company, and when you need to take concrete action, is something a lawyer or the competent supervisory authority can best advise you on. We describe the timelines as they appear in the regulation and the work plan, but we make no statement about your individual situation.
Short answer for those with little time
The statutory deadline is not yet final: a delegated act is expected in 2026, followed by eighteen months before the obligation takes effect, which amounts to an expected period around 2028. The timeframe you have in your own hands, namely collecting data, coordinating with suppliers and amending contracts, is usually the longer and more important of the two.
Do you have half an hour and want to know where you stand now? Take the free quick-scan or browse through the frequently asked questions about the digital product passport to see which part deserves your company's attention first.