According to which method must I measure the values for the passport?

What you must do concretely

What is expected of you

The measurement method follows from the delegated act for your product category

The ESPR itself does not prescribe a measurement method. Article 39 of the ESPR (Regulation (EU) 2024/1781) determines that test, measurement and calculation methods are established per product category, referring to harmonised standards or, if these do not exist, to other technical specifications designated by the Commission. This means that the question 'according to which method do I measure' receives a concrete answer only once the delegated act for the product category under which a product falls has been published. For a company with multiple product categories in its portfolio, this can thus yield several different answers, and not one uniform calculation method for the entire range. What a delegated act precisely is and why it is the starting point for every practical obligation, is the core to understand here.

The requirements in Articles 5 to 7 determine what is measured

Articles 5 to 7 of the ESPR (Regulation (EU) 2024/1781) describe the ecodesign requirements, and the distinction between performance requirements and information requirements. Performance requirements establish a level to which a product must comply (for example in the field of sustainability, energy consumption or material reuse), information requirements establish which data must be known and available. The measurement method in Article 39 is the instrument by which these two types of requirements are fulfilled: without an established method, a performance requirement is difficult to verify and an information requirement is difficult to document unambiguously. For a medium-sized company, this means that the question 'what do I need to measure' and 'how do I measure it' cannot be answered separately — both are set out in the same delegated act.

Established standards apply even if they were not chosen as the first option

Where a harmonised standard exists and has been designated by the Commission, the method to be followed is established in it. If a harmonised standard is absent, the delegated act designates another technical specification. For the practice of a company with 10 to 100 employees, it is relevant that this is not a choice: there is no choosing between 'the standard' and 'a proprietary test protocol', but following what has been designated. An in-house laboratory or external test party can carry out the measurements, but the method itself is fixed in the regulations for that product category.

The result of the measurement becomes data in the passport

The measurement results ultimately feed the data that goes into the passport: an energy value, a percentage of recycled material, a lifespan indication. Which data exactly that is and how it is displayed is described on the page about which data will be included in the digital product passport of products. The measurement method thus not only determines whether a product meets a requirement, but also what figure will be visible for buyers, supervisory authorities and other parties in the chain.

Where things go wrong in practice

A method from another product category is adopted. In companies with a broad assortment, there is sometimes an assumption that a measurement method established for product A is also usable for product B in another product category. Because each delegated act designates its own method, this assumption is not necessarily valid.

Measurement is carried out before the delegated act exists. Some companies want to be prepared in advance and have measurements carried out on the basis of a draft standard or an assumption about what is coming. If the final delegated act differs, that measurement must be done again, with the associated costs and time loss.

A test report from a supplier is adopted without verification. A supplier provides a test report, but it is not always clear whether the method in that report is the same as the method designated by the delegated act for that product category. Without that verification, a data item enters the passport that does not align with the prescribed method upon audit.

The measurement is carried out, but not documented how. The figure is recorded, but not which standard, which test setup or which version of a specification was used. In a later request from supervision or from a business relationship, it is then no longer possible to establish whether the correct method was followed.

Different departments or locations measure on their own initiative differently. In companies with multiple product lines or locations, a patchwork of test reports sometimes arises, where not every department has used the same version of the designated method.

What you can document

• Per product group: which delegated act applies, and which standard or technical specification is designated in it for the measurement.
• The test report or calculation document itself, stating the standard used, test setup and date.
• An overview of which data from the measurement flow into the passport, to be aligned with the page on which data are included in the product passport.
• When purchasing test reports from suppliers: a control agreement or record that the method used complies with the designated method for that product group.
• A point in time when measurements are reviewed, linked to the question of how often data in the passport are updated, as described on the page on how current the data in the product passport must be.
• A reference to the delegated act itself in the internal file, so that if there is a later amendment, it is clear which version was followed at the time — the background to this is explained on the page on what a delegated act is and why it determines what must happen.