My product falls under multiple product categories — what does that mean?

One product, multiple sets of requirements that apply simultaneously

If a product falls within multiple product groups, this means that for that same product more than one set of requirements can be relevant at the same time — not that multiple digital product passports are needed. The ESPR (Regulation (EU) 2024/1781) operates within a framework in which separate delegated acts per product group establish the precise requirements: which information must appear in the passport, which sustainability criteria apply, and how the product is identified. If a product meets the description of more than one product group — for example because it combines multiple functions, or contains a component that itself falls under its own regulation — the principle is that the applicable requirements from each relevant delegated act come together in one passport, linked to one unique identification code for that product.

For composite and multifunctional products, not for separate components

This issue arises especially with products that literally belong in more than one category: a device that could be assessed both as an electronics product and under a textile or furniture regulation, or an end product with an integrated battery that itself is also subject to its own regulatory framework. This does not concern a product that happens to resemble something from another group, and it does not concern accessories or spare parts that are placed on the market separately — those are assessed on their own characteristics as a matter of principle and, where applicable, receive their own passport. What it does concern: one product placed on the market for which, on the basis of its composition or functions, more than one delegated act can be relevant. Which delegated acts exactly that are and how their scopes of application relate to each other is not described in Article 9 or Article 12 itself — that follows from the text of the delegated acts established per product group.

No separate timeline for this situation yet

There is no separate timeline for products that fall within multiple groups; such a product follows the dates established for the product groups concerned separately. For a product with dual classification, this means that the passport requirement only arises once the delegated act for the group in question enters into force — and if the groups under which a product falls are regulated at different times, it is possible that a product already falls under one set of requirements while the other has not yet entered into force. For the part that is not yet regulated, no passport requirement applies on that basis until that time. At present, it is not yet established for many product groups exactly when their delegated act will enter into force; what is established is the framework from the ESPR itself within which those acts are drawn up.

How this works in practice for the passport

For anyone dealing with a product that may fall within multiple groups, the first step is to determine which delegated acts exactly apply — that determination does not follow from the ESPR itself but from the definitions and scope of the product group-specific regulations. After that, it is a matter of checking what data each applicable regulation requires for the passport, because those requirements can overlap but also supplement each other. Subsequently, one passport is compiled that contains all that data and is linked to the unique identification code of Article 12, so that the product with all its characteristics can be consulted via one access point — not via separate passports for each product group into which the product happens to fall. Where it is unclear whether a product does or does not fall under a particular group, it makes sense to clarify that on the basis of the definitions in the delegated act itself, because the qualification is determined there and not in Article 9 or Article 12.

Where this is stated: Article 9 and Article 12 ESPR

Article 9 of the ESPR (Regulation (EU) 2024/1781) describes what the digital product passport must contain and determines that the content must comply with the requirements established for the product in the applicable delegated act. Article 12 governs the unique identifier code by which a product — and thus also a product that falls under multiple regulations — remains recognisable and traceable as a single entity, regardless of how many sets of requirements are substantively applicable to it. Which product groups apply to a specific product and which requirements follow from this can be found in the delegated act established or to be established for that group or groups; the two articles mentioned only establish the structure and the link, not the substantive demarcation between product groups.

If you want to verify whether a product falls under one or multiple product groups, it is best to place the definitions in the relevant delegated acts side by side and collect the data resulting from them in advance per group, so that they can subsequently be merged into one passport.

Where this is based on

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

A product that falls under more than one product category is less exceptional than it may seem. Think of an electrical appliance with a built-in battery, or a textile product with electronic components. The ESPR regulates the digital product passport per product category, via separate delegated acts — and that means that a product with multiple characteristics may also be subject to multiple regulations.

Determining which product categories apply

For a manufacturer or importer, this first and foremost means: finding out which of the product's characteristics fall under which delegated act. This is not a legal exercise in itself, but a factual one: what is in the product, and which of those components are already (or will soon be) subject to requirements. What is a delegated act and why does it determine what I must do? explains how those regulations come about per product category and why their content can vary considerably. For a company with 10 to 100 employees, this practically means that compliance is checked not once, but potentially multiple times to determine whether and when an obligation arises.

Multiple passports can exist alongside each other

Where multiple product categories apply, this can lead to multiple passports for one physical product. A well-known example is the combination of the digital product passport under the ESPR with the battery passport under the Battery Regulation — two regulations with their own rules and their own timeline. What is the difference between the battery passport and the digital product passport? discusses how those two relate to each other. In practice, this means that a product does not automatically have "one passport"; the number depends on how many regulated components it contains and how many separate regulations apply to them.

Each passport receives its own unique identification code

Article 12 of the ESPR assigns a unique identification code to the digital product passport. Where a product has multiple passports, this also means multiple identification codes, each linked to the passport for which it was issued. For a company, this means that the codes and the associated QR data carriers are not interchangeable: each code belongs to one passport, with the data that applies to that specific product category.

The content of each passport follows its own delegated act

Article 9 of the ESPR describes what a digital product passport must generally contain, but the specific data is filled in per product category by the delegated act that applies to that category. Two passports for the same physical product can thus request partly overlapping and partly very different data. What data goes into the product passport for products? describes how that dataset is structured and why it differs per product category. For a company with multiple product categories, this means that the information is not collected once and then reused everywhere, but is reassembled per passport from the relevant sources.

Taking different timelines into account

Product categories are not made mandatory at the same time. One category may already fall under an applicable delegated act, while another category is still in preparation. In what order do product categories get a mandatory passport? shows how that sequence is structured. For a product that falls into two categories, this means that the obligation for one component can come into effect earlier than for the other — with the result that a product can temporarily have a passport for one characteristic, while the other characteristic does not yet require a passport.

Where things go wrong in practice

A common assumption is that one passport per product is sufficient, even when the product clearly consists of multiple regulated components. This leads to a passport that contains data on one characteristic, but nothing on the other — while a separate regulation applies to that.

A second situation occurs when a company determines the product category of the main component (for example, the device itself) and forgets that a supplied or integrated component — such as a battery — falls under a different regulation. The result is that one of the two obligations is simply overlooked.

A third situation arises with product lines that expand: a product that initially fell into one category receives an electronic component or battery in a later version, without the classification being reassessed. The original classification then remains decisive, even if it is no longer entirely correct.

A fourth recurring point is confusion between the identification code of one passport and that of another, especially when both are affixed to or included with the product. Without a fixed assignment, it is no longer clear which code belongs to which passport and which delegated act.

A fifth situation arises with the import of products that have already been partially documented elsewhere: the importer adopts the existing documentation for one product category, but does not check whether the product also falls under a second category that did not receive the same attention in the country of origin.

What you can document

An overview per product of the components or characteristics that may fall under their own product category, with a brief explanation of why they do or do not.
A link between each passport and the delegated act on which it is based, so that if that regulation changes, it is clear which passport must be updated.
A record of the unique identification codes per passport, including which code belongs to which physical component or characteristic.
A timeline per product category in which the product plays a role, so that it is visible which obligation already applies and which is still in preparation — this can Which product category does my product fall under? serve as a basis for the initial classification.
A documented agreement on who within the company is responsible for reassessing the classification when product changes are made, such as the addition of a new component.
A file per passport with data collected specifically for that product category, instead of a single compilation document for the entire product.

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.