must I offer the product passport in multiple languages

At least one language that the user understands

The ESPR requires that information in the digital product passport must be understandable to the user for whom it is intended, and the delegated act for each product category determines which language or languages are concretely required for that purpose. There is no fixed list of "mandatory languages" in the ESPR itself — no article that states "Dutch, French and German mandatory". What is established is the guiding principle: the passport must be useful to the end user, and information that no one can read does not meet that requirement. For a product placed on the market in the Netherlands, it is therefore logical that the language of the end user is relevant — but the binding rule on this must come from the delegated act of the product category in question, not from the ESPR in general terms.

What is regulated generically and what differs per product category

Article 10 of the ESPR (Regulation (EU) 2024/1781) describes the general requirements for the digital product passport: the passport must be accessible, reliable and understandable. Article 11 addresses the technical design and operation, such as the link with the data carrier and the way in which the passport can be consulted. Neither of these articles specifies a language requirement. That requirement, if it comes, is established per product category via the delegated acts that follow from Articles 5 to 7 of the ESPR. This means that the language requirement for, for example, textiles can work out differently than for furniture or electronics — not because the law is inconsistent, but because each product category gets its own delegated act with its own provisions. What a delegated act exactly entails and why it determines the concrete implementation is therefore relevant to understand before you expect that the ESPR itself contains a language table.

This topic is therefore not about "must the passport be multilingual" as a generic, always-applicable rule, but about a question that is answered separately per product category. For a manufacturer selling products in multiple member states, it is conceivable that the delegated act sets a requirement that differs from what applies to another product category, or that there remains room for the language of the country of first sale. What is not established on the basis of the ESPR alone is a statement as to whether one language (for example English) is always sufficient, or whether all languages of the countries where the product is sold are required.

No fixed date yet, but a fixed mechanism

There is no general date on which a language requirement for all product categories takes effect, because that requirement is established per product category in the delegated act for that category. Until such time as a delegated act for a specific product category has been adopted and enters into force, no concrete language requirement from ESPR legislation applies to that category either. What is already established is the principle from Article 10: the information must be understandable to the user. That principle applies regardless of the product category in question, even if the translation of it into a concrete language requirement has not yet been made everywhere. More about the general planning of obligations per product category is described in the question when the passport becomes mandatory for products.

What this means for your approach

The first step is to check whether a delegated act has already been established for your own product group, and if so, what it specifically states about language. That is simply where the concrete requirement is found, not in the ESPR text itself. The second step is, pending such an act, to proceed from the principle that the information must be understandable to the user in the market where the product is sold — in practical terms, this often means that the language of that country is relevant, even without an explicit legal obligation already in place. The third step is to take into account the structure of the digital product passport itself: because the digital product passport is compiled from data provided by the manufacturer or importer, it is practical to think ahead when submitting data about which fields should be filled in which language, so that any language requirement later does not mean that everything has to be redone. This aligns with the question which specific data are included in the digital product passport — the language is namely relevant per data field, not for the digital product passport as a whole at once.

Anyone who now has doubts about whether their own product falls under the ESPR at all would be well advised to answer that question first before the language question comes into play; this is explained in the question of whether the digital product passport applies to your own products.

Where this is found: Article 10 and the delegated acts per product group

This explanation follows from Article 10 of the ESPR (Regulation (EU) 2024/1781), which sets out the general accessibility and comprehensibility requirements for the digital product passport, in combination with Article 11 on its technical design and functioning. The concrete specification — which language or languages are precisely required — does not follow from these articles themselves, but from the delegated acts established on the basis of Articles 5 to 7 of the ESPR per product group.

Anyone who wants to get started now should best start by checking which product group their own product falls under and whether a delegated act has already been published for it; as long as that is not the case, it is advisable to take into account the language of the market in which the product is sold when submitting product data.