Dates and deadlines
Every date in the instrument, with its article
The duties apply from 28 June 2025. Transposition was due by 28 June 2022. The date 28 June 2027 is a narrow derogation, and only for the 112 emergency-communications duty. The transitions run to 2030, with an outer terminal limit of twenty years after entry into use.
If a paper says the deadline is 2027, it is wrong. Article 31(3) allows a member state to apply the Article 4(8) measures no later than 28 June 2027. It does not move Article 2, Article 4 or any duty for a product or service.
The timeline
- 2019-04-17Adoption. The Directive is adopted in Strasbourg. (Article 35, signature block)
- 2019-06-07Publication. Published in the Official Journal, L 151/70. (OJ masthead)
- 2019-06-27Force. Enters into force, twenty days after publication. (Article 34)
- 2020-06-28Delegated. Latest date for the first delegated act on the Annex VI criteria, if needed. (Article 14(7))
- 2021-06-28Standard. Latest date for the first draft request for harmonised product standards. (Article 15(2))
- 2022-06-28Transposition. Member states were to adopt and publish the national measures. This was the transposition deadline. (Article 31(1))
- 2025-06-28Application. The national measures apply. Products first supplied and services first provided from this date are covered. (Article 31(2), Article 2)
- 2025-06-28Cutoff. Cut-off for the legacy content exclusions and for products lawfully used before the transition. (Article 2(4), Article 32)
- 2027-06-28Derogation. Latest date for the Article 4(8) duty on answering 112 emergency communications, and only where the member state uses the derogation. (Article 31(3))
- 2030-06-28Transition. End of the service transition for products lawfully used before 28 June 2025, and outer limit for service contracts agreed before that date. (Article 32(1))
- 2030-06-28Review. First Commission report on the application of the Directive. (Article 33(1))
- 2045-06-28Transition. Outer limit of the twenty-year self-service terminal transition for a terminal first used on 28 June 2025. (Article 32(2))
When the duties start
Article 2(1) reaches products first supplied in the Union from 28 June 2025. Article 2(2) reaches services offered to consumers from that date. Article 31(2) required the national measures to apply from that date. A product first placed before the date is outside the product duties, but a new model or a first placing in the Union after the date is caught.
The date is not the date of the last sale, the date of the design freeze or the date of a contract. It is the first making available in the Union in the course of commercial activity. Keep the evidence for that first event.
What 2027 actually means
Article 4(8) requires the answering of 112 emergency communications by the most appropriate public safety answering point to meet Annex I Section V. Article 31(3) lets a member state decide to apply the measures for that obligation no later than 28 June 2027. If the member state does not use the option, the duty applied from 28 June 2025 with the rest.
The transitions
Article 32(1) lets a service provider continue to use products lawfully used before 28 June 2025 to provide similar services until 28 June 2030. A service contract signed before that date may run unchanged to its end date, subject to a ceiling of five years counted from 28 June 2025. Article 32(2) allows self-service terminals lawfully used before that date to stay in service for as long as they remain economically worth keeping, capped at twenty years from entry into use.
The transitions protect an installed base. They do not cover a product bought after the cut-off or a contract extended after it. Build the registers before the first replacement decision, not after.