The Digital Product Passport timeline for Swiss manufacturers

The Digital Product Passport is often described to Swiss manufacturers as a European regulation with delayed relevance for Switzerland. That reading fails on both counts. The obligation attaches to products placed on the EU market whatever their country of manufacture, and Swiss law is moving to require passports domestically for some categories. The question is not whether the DPP applies to you, but which deadline reaches you first, through which market, and whether it arrives on your own product or in your supply chain.

Bottom line up front: The Digital Product Passport reaches Swiss manufacturers as a series of sector-specific deadlines running from February 2027 to the end of the decade, triggered by the EU market rather than by Swiss membership, and now heading into Swiss law for construction products and toys. Read as a compliance calendar, it is a list of separate projects. Read as an architecture signal, it is one thing arriving in installments, and it rewards the manufacturer who builds a single governed foundation that absorbs each new delegated act.

Why the EU market sets your clock

Any Swiss manufacturer selling batteries, textiles, steel, aluminum, or the other named categories into the EU faces the same deadlines as an EU competitor, on the same dates. The EU is Switzerland’s largest export market by a wide margin, so for most Swiss industrial producers the EU calendar is the operative one whether or not Swiss law ever mentions the DPP. The domestic picture is moving too: GS1 Switzerland’s position is that toys and construction products will require a passport on the Swiss market as well, on a slight delay behind the EU. That is not yet enacted, since it depends on revisions to Swiss legislation including the Federal Act on Construction Products, but the direction is clear enough to plan around and more categories may follow.

The EU infrastructure, meanwhile, is already live. The Commission’s central DPP registry (just recently) launched in July 2026, with implementing rules on access management, user verification, and data registration following weeks later. No product-specific ESPR delegated act is yet in force, so nothing obliges you to publish a passport today, but the plumbing you will publish into now exists and can be built against. That matters because the data a passport needs originates upstream in engineering, sourcing, and quality rather than at the export step. A manufacturer that waits for its sector’s dates to be confirmed finds the runway short and the information it needs never captured at source.

The deadlines that reach a Swiss manufacturer

Two dates get quoted for each sector, which is why published timelines contradict each other: the date a delegated act is adopted, and the date obligations take effect. They sit eighteen months to two years apart. The dates below are when obligations take effect, except where a regulation fixes the date itself, and for most ESPR categories they will not be settled until each act is published.

February 18, 2027 - Batteries. The first hard deadline, set by the EU Battery Regulation 2023/1542, covering light means of transport batteries, industrial batteries above 2 kWh, and electric vehicle batteries. From this date no battery in these categories may be placed on the EU market without a compliant passport. The date holds even though supporting technical measures are still being finalized, including the standard governing access rights.

Around 2028 to 2029 - ESPR first wave: iron and steel, textiles, tires, aluminum. The Commission’s Ecodesign working plan for 2025 to 2030 names iron and steel, textiles and apparel, furniture, mattresses, tires, and aluminum as the priority groups. Iron and steel is first, with its delegated act expected in 2026 and obligations around 2028. Textiles, tires, and aluminum follow, with adoption expected in 2027 and obligations largely in 2029. Swiss exposure is significant across steel, textiles, and aluminum extrusion, and reaches beyond the producers themselves: iron, steel, and aluminum are regulated here as intermediate products.

Around 2029 to 2031 - ESPR second wave: furniture and mattresses. Furniture delegated acts are expected in 2028 and mattresses in 2029, with obligations following into 2030 and 2031. Chemicals, detergents, paints, lubricants, and footwear sit outside the first working plan: detergents are regulated separately under the Detergents and Surfactants Regulation, and the others await further study.

Late 2020s into the early 2030s - Construction products under the revised CPR. The revised Construction Products Regulation 2024/3110 entered into force in January 2025 and applies in stages from January 2026, embedding a construction-specific passport intended to interoperate with the Ecodesign framework. First delegated acts are expected from 2026, and manufacturers get eighteen months from the entry into force of the act covering their product. Obligations therefore arrive family by family, the earliest phasing in from 2027 and heavier lifecycle data requirements landing well into the next decade. Swiss construction-product makers face this on both markets, with the transition supported through GS1 Switzerland’s construction-sector work and the wider Bauen digital Schweiz community.

August 1, 2030 - Toys. The Toy Safety Regulation (EU) 2025/2509 was published in December 2025 and applies in full from August 1, 2030, a transition of roughly fifty-four months. That date is fixed in the regulation rather than dependent on a delegated act, which makes it the most certain date on this calendar after batteries. The technical specification for the toy passport still has to arrive by delegated act, so what you will publish is not yet fully defined even though when you publish it is. The passport replaces the physical Declaration of Conformity, and customs authorities must be able to verify it before imported toys enter the market. Toys are the other category heading into Swiss law behind the EU.

What changes each time, and what does not

Every one of these regimes asks for the same handful of things: structured, machine-readable data tied to a unique product identifier through a data carrier; information that stays available and current across the product’s life; verifiability against an authoritative source; and access rights that differ by actor, from consumer to repairer to recycler to regulator. The technical regimes are converging on the same EN 18xxx family of harmonized standards, built on GS1 identifiers such as the Digital Link, with the battery and construction tracks running their own standardization intended to interoperate with it.

What differs is the specific data required. Batteries require carbon footprint, state of health, recycled content, and hazardous substance information, all set in the regulation. The others are anticipated rather than final, because their delegated acts do not yet exist: textiles are expected to require fiber composition, chemical treatment, and country-of-origin data; steel and aluminum, alloy composition and embodied carbon; furniture, wood sourcing and volatile organic compound emissions; construction products, declaration of performance data under the CPR. Those differences shape what you collect upstream from suppliers. They do not require a different data architecture per sector.

Passport data arrives even if your product is not in scope

Because iron, steel, and aluminum are regulated as intermediate products, their passports travel downstream.

A Swiss machinery builder, electrical equipment manufacturer, or precision component supplier may have nothing of its own in the first wave. From 2028 and 2029, its metal inputs start arriving with passports attached, carrying alloy composition, recycled content, and embodied carbon. Customers and their regulators will expect that information to be available for the finished assembly, which means receiving it, holding it against your own product records, keeping it current as suppliers reissue it, and exposing the relevant parts onward. That is a data problem rather than a compliance problem, it lands on a far larger share of Swiss industry than the named categories suggest, and it is the same problem the categories in scope are already solving. Without somewhere governed to put inbound passport data, you accumulate supplier PDFs and no reliable way to answer a question spanning them.

One category still means repeated change

Being in a single category does not mean facing this once. A delegated act gets revised. The reference data it points at is updated as classifications and thresholds change. Access designations shift as the standard governing them finalizes, expected around September 2026. The harmonized standards are landing in stages. For construction products and toys, a Swiss requirement is expected behind the EU one, putting the same product under two instruments with different timing. A minority of manufacturers, mostly in construction materials and metals, will also span more than one category outright.

Alongside that sits adjacent regulation drawing on the same upstream data. Packaging rules, carbon reporting, and supply chain due diligence each want structured, verifiable information about materials and provenance. None of them are the DPP, and all of them ask your engineering, sourcing, and quality functions the same kinds of question.

A delegated act is not a new program but a change to the model, the reference data, or the access rules of a foundation you already have. Every deadline on the calendar reduces to some combination of those three, which is why the manufacturers who treat each act as configuration absorb it while the ones who treat each act as a project rebuild every time.

Simple Steps for COOs

• Map your exposure in both directions. For each product line you sell into the EU or place on the Swiss market, note which regulation covers it and when its obligation takes effect. Then do the same for what you buy: if your bill of materials contains steel, aluminum, textiles, or tires, passport data starts arriving from suppliers in 2028 and 2029 whether or not your own product is in scope. Your first infrastructure deadline is the earlier of those two dates.
• Design for the update, not the deadline. Each act arrives as some combination of three changes: new or altered data fields, new reference data such as classifications and thresholds, and new access rights governing who can see or write which fields. Build so all three are governed configuration changes to one foundation, and pressure-test that by asking how your systems would absorb a new field, a new code list, and a new access rule.
• Make your platform vendor show you the second act, not the first. Any vendor can produce a passport for one category. Ask them to walk through how their platform takes on the next delegated act, whatever combination of new fields, reference data, and access designations it brings, without a rebuild. Configuration means you are looking at a foundation; anything else is a point solution for your first deadline.

This article is by Matt Shearer, COO at Data Graphs. Based in Zurich, Data Graphs is a knowledge graph platform and GS1 Switzerland Solution Partner, helping manufacturers build the information backbones that produce Digital Product Passports. To discuss your DPP roadmap, contact us.

Sources

The Digital Product Passport timeline for Swiss manufacturers. Primary sources July 2026.

EU legislation and Commission documents

Regulation (EU) 2024/1781 — Ecodesign for Sustainable Products Regulation Legal basis for the Digital Product Passport. Article 13 establishes the DPP Registry.
Regulation (EU) 2023/1542 — Batteries and Waste Batteries Article 77 sets the battery passport obligation from 18 February 2027.
Regulation (EU) 2024/3110 — revised Construction Products Regulation Establishes the construction-specific passport. Entered into force January 2025.
Regulation (EU) 2025/2509 — Toy Safety Regulation Published 12 December 2025, applies in full from 1 August 2030. The passport replaces the Declaration of Conformity.
Commission Implementing Regulation (EU) 2026/1778 Of 16 July 2026. Implementation arrangements for the DPP Registry: access management, user verification, data registration, technical architecture.
Ecodesign and Energy Labelling Working Plan 2025-2030, COM(2025) 187 final Adopted 16 April 2025. Six priority groups split into four final products and two intermediate products, with indicative adoption dates and a 2028 mid-term review.
European Commission Green Forum — 2025-2030 working plan Commission commentary on delegated act sequencing.

Swiss federal sources

KBOB — Grundlagenpapier Digitaler Produktpass Coordination Conference of Public Sector Construction and Property Bodies, July 2025. Swiss federal position paper on the DPP.
Bundesgesetz über Bauprodukte (BauPG), SR 933.01 The Swiss construction products law requiring revision before a domestic passport obligation applies.
Bundesamt für Bauten und Logistik — Rechtsgrundlagen, Fachbereich Bauprodukte BBL is the federal office responsible for the BauPG revision, which began in Q4 2024.

GS1 sources

GS1 Switzerland — Digital product passport Swiss market position, GS1 standards basis (GTIN, Digital Link, ISO/IEC 15459), and Swiss pilot projects.
GS1 Switzerland — Whitepaper: Digitaler Produktpass Construction-sector whitepaper. Source for the Swiss construction products position pending BauPG revision.
GS1 Switzerland — Whitepaper: Digital vernetzte Bauproduktdaten Bauen digital Schweiz / buildingSMART Switzerland foundation paper on connected construction product data.
GS1 Switzerland — All about the digital product passport Overview of the phased EU obligation from 2027 and GS1 Switzerland’s industry work.