Does each component get its own passport or the product as a whole?
Usually one passport, with room for components
The ESPR's starting point is one digital product passport per product. However, the regulation does not exclude the passport being composed of the passports of the components that make up the product. Article 11 of the ESPR (Regulation (EU) 2024/1781), which describes the technical design of the passport, deliberately leaves this possibility open: for products composed of components, parts or subassemblies, the passport of the whole can be linked to the passports of those separate parts. Whether this actually applies to a specific product is not determined in the ESPR itself. This is laid down per product group in the delegated act drawn up for that group. For most products that already fall under ecodesign rules or will soon fall under them, it has therefore not yet been clarified whether components will have their own passport or whether everything is combined in one passport at product level.
For whom this is relevant — and for whom it is not
This question is particularly relevant for products composed of components that themselves may also be subject to ecodesign requirements, or that are produced by a different market participant than the final product. Think of a device with a replaceable battery, a motor purchased separately, or a module that also comes onto the market as a standalone item. For a single product without relevant sub-components — a simple article that is produced and sold as a whole — the question is less practically relevant: one passport at product level would be the obvious approach. It is also important to make this distinction: this concerns the question of whether components will have their own passport, not the question of what data must be in that passport. The latter is determined separately per product group, independently of the structural question at issue here. And this also does not concern spare parts that are sold separately after purchase of the main product — that is a different matter addressed elsewhere in the ESPR.
No fixed date yet: the product group determines this
There is no general date on which it becomes clear whether components will have their own passport. This is because the ESPR does not make this choice itself, but defers it to the delegated acts per product group. As long as no delegated act has been adopted for a particular product group, there is also no answer to the question of whether components of products in that group will have their own passport. Until then, it is established that a unique identification number will be linked to the passport, as Article 12 of the ESPR describes, and that the technical design of the passport must be set up in such a way that links between passports are possible when relevant for a product group. The precise implementation — which product groups will use this, and for which components — thus follows per delegated act, and these are published successively for different product groups.
What this means for the structure of your passport
For a manufacturer or importer dealing with multiple product groups, the practical sequence is as follows. First, you check which delegated act applies to the product in question, and whether it contains anything about passports at component level. Next, you map out which parts of the product itself already fall under ecodesign requirements or may do so in the future — for example, because they are also placed on the market separately. After that, it is important to determine whether the supplier of such a component already has its own product data that can be included in a linked passport, and whether your own data organization is set up in such a way that a link between the passport of the end product and that of a component is technically possible. For companies that sell products in multiple product groups, it is practical to assess this structural question separately for each group: what applies to one product does not necessarily apply to another, precisely because each delegated act makes its own choice.
The basis: Article 11 and 12 of the ESPR
That a passport can consist of linked passports of components follows from Article 11 of the ESPR (Regulation (EU) 2024/1781), which regulates the technical design and operation of the digital product passport. That a passport — and thus also a component thereof — receives its own unique identification code follows from Article 12 of the same regulation. Both articles leave the specific implementation for a particular product group to the delegated act that is adopted for that group: the ESPR itself does not require passports at component level, but makes it possible where it is considered appropriate for a product group.
Anyone who wants to know whether this applies to their own product should consult the delegated act for the relevant product group as soon as it is published, and in the meantime map out which components of the product could be independently relevant for a linked passport.
Where this is based on
- Regulation (EU) 2024/1781 (ESPR), Article 12 (unique identifier code)
- Regulation (EU) 2024/1781 (ESPR), Article 11 (technical design and operation of the digital product passport)
The regulation itself is on EUR-Lex. We provide references for each claim; you do not have to take our word for it.
What you must do concretely
What is expected of you
The ESPR regulates the digital product passport at the level of the product placed on the market, not automatically at the level of each component within it. But "the product" is not always the same as "one physical entity" — and that is precisely where the question becomes complicated for a company that manufactures or imports composite products.
Determining what the product to be identified is
Article 12 of the ESPR (Regulation (EU) 2024/1781) requires a unique identification code per product. What counts as "a product" in this context is specified per product group in the delegated act. For a manufacturer with 10 to 100 employees, this means in practice that the arrangement of the assortment must be reviewed: is the washing machine one product with one passport, or do the motor and the electronics module within it also receive their own identification code because they themselves fall under a product group? That distinction determines whether one unique identification code per product is sufficient, or whether a structure of underlying codes is required.
Aligning the technical design with the product structure
Article 11 of the ESPR describes how the digital product passport is technically set up, including the possibility of linking passports. For companies that assemble products from components that have their own passport obligation — think of a battery in an electrical appliance — this means that the passport of the final product cannot stand alone from the passport of that component. How these two passports practically relate to each other depends on the product groups involved; see how multiple product passports for one product work together for the way in which that interplay is set up.
Deciding whether components are linked to each other or remain separate
When a component itself is subject to a passport obligation, the question arises whether that passport refers to the passport of the final product, or vice versa, or both. This is not a matter of preference but of what the technical design in Article 11 allows and what the product group rules prescribe. For a medium-sized company that, for example, purchases motors and processes them into its own final product, this means that it must be clear in advance who manages which passport and how passports are linked to each other.
Ensuring that the identification code indicates the correct level
A unique identification code that is accidentally assigned at the wrong level — for example one code for an entire product line instead of per individual product — results in a passport that does not comply with what Article 12 requires. For companies working with batch production (the same code for an entire batch), this is a real point of attention: the code must indicate the level that the regulations require for that product group, not the level that is administratively easiest.
Where things go wrong in practice
A manufacturer of kitchen appliances treats the separate battery in a hand mixer as an accessory, without checking whether that battery itself falls under the Battery Regulation and has its own passport obligation. The final product receives a passport, the battery does not — while it can be sold separately and replaced.
An importer of furniture with integrated electronics (lighting, adjustable parts) assumes that one passport for the entire piece of furniture is sufficient, without investigating whether the electronics module falls under a different product group with its own requirements.
A company that combines components from different suppliers into a final product assigns the final product a new identification code but in doing so loses track of the identification codes that the suppliers had already assigned to their own components. In the event of a recall, it is then impossible to trace which passport belonged to which component.
A manufacturer decides on its own, without consulting the product group rules, that "one passport per sales unit" is the practical standard — and later discovers that the delegated act for that product group uses a different starting point.
A company manually updates the passport of the end product following a change in a component, but the passport of that component itself remains unchanged, so the two passports no longer correspond with each other.
What you can document
- An overview per product group of what qualifies as "the product" according to the applicable delegated act: the end product, a module, or both.
- A diagram of the product structure indicating which components have their own passport obligation and which do not.
- Agreements with suppliers on who assigns and manages the identification code of a component, and how that information is passed on when the end product is assembled.
- A procedure for assigning a unique identification code at each level required by the regulations, including who within the company makes the decision on this.
- A documented method for linking passports, so that changes in a component passport are also traceable in the passport of the end product.
- Documentation of the assessment made when in doubt about the level of classification — useful during a later inspection or when questions arise from a supervisory authority.
Prodpas.eu makes templates available for product structure registration and for agreements with suppliers on identification codes, so that this documentation does not need to be developed from scratch for each product group.
This is not legal advice. This page provides general information about the regulations that this platform concerns. We do not know your situation. If you are in doubt about your own case, consult a lawyer or the competent supervisory authority.
Written with AI on the basis of the sources above, checked by a human on 2026-08-22. Is something incorrect? Let us know — corrections are given priority.