European Product Act: what it is, what changes, and what the deadlines are

AI generated

If you produce, import, or distribute goods within the European Union, product legislation is about to undergo profound changes. The European Commission has presented the package known as the <a href="https://europarl.europa.eu/RegData/etudes/BRIE/2026/789349/EPRS_BRI(2026)789349_EN.pdf">European Product Act</a>, a reform designed to update legislation for digital commerce, accelerate the circular economy, and protect the single market from non-compliant goods.

In this article, we take stock of <b>what it is, which laws it modifies, the deadlines to monitor</b>, and how technologies like the <b>Digital Product Passport (DPP)</b> will allow you to adapt without disrupting your processes.

The European Product Act is not a single isolated law, but an <b>integrated legislative package</b> that reforms the foundations on which the compliance and safety of products in the EU are based.

The need for this intervention stems from two major market transformations:

• <a href="https://taxation-customs.ec.europa.eu/customs/eu-customs-union-facts-and-figures/goods-bought-online_en">The explosion of extra-EU e-commerce</a>: in recent years, the volume of low-value goods (under €150) shipped directly to European consumers from third countries has reached record numbers (over 5.8 billion estimated shipments). A large part of these products slipped through the traditional meshes of customs and safety controls.
• <a href="https://www.mesopartner.com/post/the-eu-s-new-legislative-framework">The transition to the circular economy</a>: the old legislative framework treated product compliance in a "static" way, meaning limited to the moment it was first placed on the market. Today, the EU requires "dynamic" compliance that tracks the product throughout its entire life cycle (repair, reuse, recycling).

Revision of the New Legislative Framework (NLF)

The NLF framework dated back to 2008. The revision introduces two crucial novelties:

• <b>Digital Product Passport (DPP)</b>: the Digital Passport becomes the tool of choice for storing and sharing data on the composition, environmental impact, repairability, and compliance of products.
• <b>Circular compliance</b>: compliance does not end at the time of the first sale. If a product is refurbished, repaired, or recycled, its history and compliance must be updated in the traceability IT system.

Revision of the Market Surveillance Regulation (MSR)

This measure serves to "close the loopholes" of e-commerce:

• <b>Marketplace Responsibility</b>: in line with the <a href="https://it.wikipedia.org/wiki/Digital_Services_Act">Digital Services Act (DSA)</a> and the <a href="https://eur-lex.europa.eu/EN/legal-content/summary/general-product-safety-regulation-2023.html">General Product Safety Regulation (GPSR)</a>, e-commerce platforms will have to implement "compliance by design". They will no longer be able to host sellers who do not provide certain data on product traceability and safety.
• <b>European governance of surveillance</b>: strengthening controls at the EU borders and enhancing rapid alert systems (such as the <a href="https://ec.europa.eu/safety-gate/#/screen/home">Safety Gate</a> circuit) to quickly withdraw dangerous or counterfeit products from the market.

Revision of the Standardisation Regulation

Historically, the creation of harmonised technical standards took years. To avoid bottlenecks:

• <b>Common Specifications (<a href="https://health.ec.europa.eu/medical-devices-vitro-diagnostics/common-specifications_en">Common Specifications</a>)</b>: if European standardisation bodies are slow to define a standard, the European Commission may temporarily adopt common specifications to allow companies to certify the safety of their products without remaining blocked.

The reform concerns the vast majority of physical goods placed on the single market, but the introduction of the requirements (especially for the Digital Passport) will happen in stages by product category.

Among the first sectors directly impacted by the regulations related to the DPP are:

• <b>Batteries and accumulators (digital passport obligations already operational from 2027)</b>
• <b>Textiles and clothing</b>
• <b>Construction products</b>
• <b>Toys and consumer electronics</b>

However, with the European Product Act, the Digital Passport structure becomes the standard infrastructure for all regulated industrial sectors in the EU.

It is essential to distinguish the political adoption of the law from its practical application for brands:

• <b>Late 2026</b>: presentation of the legislative package and start of the debate between the EU Council and the European Parliament for final approval.
• <b>2027</b>: formal entry into force of the package and launch of the first Digital Product Passport obligations for pilot sectors (e.g., industrial batteries and automotive).
• <b>2028-2030</b>: progressive extension of the DPP and enhanced traceability obligations to all other manufacturing sectors and e-commerce.

<b>N.B.</b>: Adapting supply chains and corporate data management takes an average of 12 to 18 months. Waiting until the ultimate deadline means risking operational blocks or penalties for non-compliance.

The main challenge of the European Product Act is not only legal, but <b>technological</b>. Companies must collect data from different suppliers, ensure that it is unalterable, and make it accessible to the end consumer and the authorities.

How to simplify this transition:

• <b>Integration without chaos</b>: connect your existing systems (ERP, PLM) to automatically generate Digital Product Passports that comply with EU standards.
• <b>Dynamic data management</b>: update the product status throughout its life cycle (warranties, repairs, recycling) while keeping the compliance certification valid.
• <b>Supply chain and post-sales visibility</b>: turn a regulatory requirement into a product governance tool. Monitor the life cycle of your goods, facilitate the management of returns and warranties, and guarantee the traceability of components along the entire supply chain.

Adapting your supply chain to the new European Union requirements takes time and planning. Structuring the data architecture today allows you to avoid operational interruptions and penalties when the individual sector regulations become executive.

To understand how to adapt your product catalog to future European requirements, <a href="https://anchorpass.eu/en/demo">contact the Anchorpass team for a technical consultation</a>.