What is the register of digital product passports and what must I enter in it?
The register links identification codes to the passport, not the complete data
The European register of digital product passports is a central system established and managed by the European Commission, in which unique identification codes are stored: of the product, of the manufacturer or importer, and of the production facility. The register does not contain the passport itself with all product data — that remains, depending on how it is set up, with the manufacturer, importer or a service provider such as prodpas.eu. The register is rather a reference system: it records which unique code belongs to which product, which economic operator and which location, and links that code to the place where the actual passport can be found. In addition, there will be a public web portal through which customs authorities, market surveillance authorities and to a certain extent the public can search that register.
For product categories with a mandatory passport, not for all products
The register applies to products for which a digital product passport has been made mandatory on the basis of a product category-specific delegated act. For those products, the economic operator placing the product on the market or making it available — usually the manufacturer or importer — is the one who must have the corresponding identification codes entered in the register. For products for which no product category regulation with a passport obligation has yet been established, there is also no registration obligation: the general provisions on the register in Articles 13 and 14 of the ESPR (Regulation (EU) 2024/1781) are only fleshed out and become applicable once the specific delegated act for that product category provides for it. The register is furthermore not a replacement system for hosting the passport itself, nor a replacement for the data carrier (such as the QR code) that is on or with the product. These are three different, interrelated components: the data carrier on the product, the passport with the data, and the register with the identification codes that refer to that passport.
No fixed date; the registration obligation follows the product category
There is no general entry date for the register that applies to all products at the same time. The obligation to have identification codes registered arises at the moment when a delegated act for a product category enters into force that makes the digital product passport mandatory for that category. Until that time, there is no registration obligation for those products, and nothing needs to be entered in the register. What is certain: the Commission is responsible for establishing and managing the register itself (Article 13 ESPR) and the associated web portal (Article 14 ESPR), regardless of which product categories already fall under it. For the question of whether and when a specific product category is to be covered, the text of the relevant delegated act for that category is the source, not a general date from the ESPR itself.
What the reader does with this, in order
First, it is relevant whether the product falls under a product category for which a delegated act establishing a digital product passport requirement has been adopted — without that act, there is nothing to register. If that is the case, the next step is to determine the unique identification codes: that of the product, of the market operator (manufacturer, importer or authorised representative) and of the production facility, insofar as these are required for the product category in question. These codes are subsequently entered into the register, before the product is placed on the market or made available — this is done via the system made available by the Commission for this purpose. In parallel, the passport itself, with the complete product data, continues to be hosted elsewhere (for example by prodpas.eu) and linked to the data carrier on the product. The register and the data carrier thus point to each other and to the passport, but are not replacements for each other. Finally, it is important that the web portal of Article 14 is the reference point by which supervisory authorities and customs can verify this link, which means that correct and timely registration also has practical consequences for how smoothly inspections proceed.
Where this is stated: Articles 13 and 14 of the ESPR
The obligation to establish a register of digital product passports, and the role of unique identification codes for product, market operator and location therein, derives from Article 13 of the ESPR (Regulation (EU) 2024/1781). The accompanying web portal by which data from the register are made searchable is set out in Article 14 of the same regulation. Both articles form the framework at regulation level; the concrete implementation per product category — which codes exactly, and from which point in time — follows from the delegated acts that are adopted for that product category.
Anyone wishing to know whether this already applies concretely to their own product should first look at the delegated act for their own product category: if a digital product passport requirement is stated therein, the registration obligation applies; if it is not yet there, there is currently nothing to register and it is sufficient to follow the developments for that product category.
Where this is based on
- Regulation (EU) 2024/1781 (ESPR), Article 13 (register of digital product passports)
- Regulation (EU) 2024/1781 (ESPR), Article 14 (web portal for data in 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 register of digital product passports is a central European facility in which certain data from the passport are stored as soon as a product is placed on the market. Article 13 of the ESPR (Regulation (EU) 2024/1781) describes this register; Article 14 describes the web portal through which competent authorities and other stakeholders can access that data. For a manufacturer or importer, this means that the passport must not only accompany the product itself (via the QR code), but that part of its content must also be traceable separately, via the register.
Registration before the product is placed on the market
The registration obligation means that the relevant data must be in the register before the product is sold or imported. For a business of any significant size, this means that creating the passport and registration in the process must be built in before market introduction — not as a final step, but as a prerequisite. For companies working with multiple product lines, this becomes a planning issue: registration must be completed before the first delivery leaves, which means that the data must be complete earlier than may previously have been customary, for example with CE documentation.
Providing the correct identification data
The register works with identification codes that uniquely identify the product, the market actor and the passport itself. This requires a consistent coding method throughout the entire organisation — something that many companies with multiple product groups (electronics, textiles, furniture) struggle with because each department sometimes uses its own system. How each product receives a unique identification code is therefore not only a technical question but also an organisational one: who assigns that code, and how do you ensure that no duplicate or missing codes arise as your assortment grows.
Ensuring the link between product and register is correct
The QR code on the product must ultimately point to the same data that is also recorded in the register. This requires coordination between the way in which the QR code for the product passport appears on products and the way registration in the register takes place. For companies that work with parties such as printers, label makers or external packers, this means that the identification code on the label and the code in the register must match at all times — a small change in one system without adjustment in the other leads to a mismatch.
Keeping registered data up to date
A passport is not a snapshot; data can change (supplier, composition, repair information). For a mid-sized company, this means that there must be a set time or process in which changes are also processed in the register, not only in the internal system. If you work with an ERP or inventory system in which product data is already stored centrally, you may wonder whether linking the product passport to your own ERP or inventory system helps to make that updating less error-prone than manual maintenance.
Where things go wrong in practice
Registration as the last step instead of the first. A company only creates the passport once the first shipment is already on its way to the customer, so that registration and dispatch are no longer in the correct order.
Different identification codes in different systems. The code that the logistics department uses for inventory management differs from the code sent to the register, so that a competent authority scanning the QR code sees a different set of data than expected.
Changes that are processed internally but not externally. A supplier change or material modification is updated in the internal quality system, but no one is tasked with also having that same change processed in the register.
Unclear who within the organisation is responsible. In companies with multiple product groups, situations sometimes arise where it is unclear whether registration for product group A is set up in the same way as for product group B, resulting in one complying with the registration obligation while the other does not.
Confusion between the passport itself and its registration. Some companies believe that creating a passport (with QR code on the product) automatically includes registration in the European register, whereas these are two distinct steps.
What you can document
- An overview of which product groups within the organization require a digital product passport, and whether these product groups multiple product passports for one product require.
- An internal process that records at what point in the chain — before market introduction — the registration in the European register takes place, including who carries out or verifies this.
- A fixed procedure for assigning identification codes, so that the same code is used throughout the organisation, from production to registration to the label on the product.
- An agreement on who communicates changes to product data (supplier, composition, repair data) to the party managing the registration, and within what timeframe this takes place.
- A verification moment to check whether the data behind the QR code on the product matches what is recorded in the register — relevant in case of doubt about how this relates to GS1 Digital Link as the underlying technical standard.
- A documented procedure for the situation in which a company ceases operations or changes ownership, so that it is clear what happens to the registration — a question that is linked to what happens to the product passport when a company ceases operations.
- An overview of the expected availability period of registered data, to be aligned with internal retention periods, as described in the question of how long a product passport must remain available.
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.