must the product passport also be available offline without internet
No, the passport is an online service
The digital product passport is designed as an online service: the QR code or other data carrier on the product points to data that are retrieved via the internet, not to a file that is stored entirely on the product or packaging itself. There is no provision in the ESPR that requires the passport to be fully accessible without an internet connection. What is fixed, however, is that the data carrier on the product continues to work and that the data it points to remain accessible throughout the entire prescribed period — and that is something different from "working offline".
What the data carrier does and does not contain itself
The data carrier — usually a QR code — does not contain product data itself. It contains a reference: a unique identification code that leads to the place where the data are stored. This means that scanning the code without an active internet connection on the scanning device yields nothing, because the code itself is not a mini-database. This applies to the passport as a whole, to all product groups that will fall under the ESPR. It does not apply to situations where a manufacturer chooses, in addition to the mandatory passport, to place additional information physically on the product or in the packaging — that is permitted, but it does not replace the passport and is not an obligation that follows from the regulation. It also does not apply to the question of whether a user without a smartphone or scanner can access the data: the ESPR regulates that there must be other ways to request the information, but that is a different point than "working offline".
Whoever wonders how that reference looks technically and what exactly it contains will find this at how to give each product a unique identification code and in what GS1 Digital Link is and whether it is necessary for the digital product passport.
This is already fixed, regardless of the implementation date
For individual product groups, it remains to be seen from what point the passport becomes mandatory — this varies per product group and is determined per delegated regulation. What is already fixed, regardless of that date, is the technical setup: the passport works via an online retrievable set of data, linked to a data carrier on the product. This setup is set out in the ESPR itself and does not change per product group. Until the moment a product group becomes mandatory, there is simply no passport requirement for that group, and therefore no question about offline accessibility — that question only arises once the passport is mandatory for a product.
What this means for setting up the passport
For those setting up a passport, the practical sequence is as follows. First: the data carrier on the product must continue to work, even after years of use, transport or storage — this is a physical requirement, separate from the question of whether the underlying data are online. If the code is damaged or becomes illegible, a different problem arises than an offline-related issue; more on this can be found at what happens if the QR code on the product is damaged or becomes illegible. Next: the data behind the code must be accessible as long as the requirement applies, which in practice means that there is a hosting solution behind it that does not depend on the continued existence of one company — see also how long a product passport must remain available and what happens to the product passport if a company ceases operations.
For the entrepreneur concerned about practical situations without network coverage — a warehouse without wifi, an inspection location in a basement, an export market with poor coverage — the key question is therefore not whether the passport "must work offline", as the regulation does not require this. The relevant question is whether the data are robustly and permanently available online, once there is a connection. This is a hosting issue, not a design requirement for offline functionality.
The legal basis: Article 10 and Article 11 of the ESPR
Article 10 of the ESPR (Regulation (EU) 2024/1781) describes the requirements for the digital product passport, including that data must be accessible to relevant parties via the data carrier. Article 11 governs the technical design and operation of the passport, and is based on a system in which data are provided via an online-queryable structure, linked to a unique identification code as detailed in Article 12. Article 13 furthermore governs the register of digital product passports, in which (metadata of) passports are recorded — this too is an online provision. None of these articles contains a requirement that the passport must be fully functional without an internet connection; the emphasis is on accessibility, durability of the data carrier and linking with a centrally queryable dataset.
What to do now
Anyone setting up a passport can therefore better focus attention on reliable, long-term hosting of the data and a physically durable data carrier, rather than on building an offline functionality that is not requested. For those tackling multiple product groups at the same time, it is also worth considering how data from your own ERP system can automatically flow through to the passport, so that the online information always remains up to date — see linking to your own ERP or inventory system and have data automatically updated.
Where this is based on
- Regulation (EU) 2024/1781 (ESPR), Article 10 (requirements for the digital product passport)
- Regulation (EU) 2024/1781 (ESPR), Article 13 (register of digital product passports)
- Regulation (EU) 2024/1781 (ESPR), Article 11 (technical design and operation of the digital product passport)
- Regulation (EU) 2024/1781 (ESPR), Article 12 (unique identifier code)
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 product passport is at its core a digital document: data that are retrieved via a data carrier on the product, usually a QR code. Article 10 of the ESPR (Regulation (EU) 2024/1781) describes the requirements for that digital passport, and Article 11 addresses the technical design and operation thereof. With regard to the question of whether the passport must also be consultable without an internet connection, these articles provide no explicit "yes" or "no" — the text is based on a digital, online queryable document that is accessible via the data carrier and the underlying system. What that means in practice breaks down into a few points.
The passport is an online queryable file, not an offline copy on the product
The structure that the ESPR has in mind is that the QR code or other data carrier on the product points to data that are kept and displayed elsewhere — with the manufacturer, importer or a hosting party. That is precisely why Article 11 speaks of the technical design and operation of the passport: the data carrier itself does not contain the full content, but a reference. For a company of 10 to 100 employees, this means that no separate "offline file" needs to be developed that works independently of the internet — the standard route remains and will remain an online environment that is accessed via the code. How that reference works exactly and which technical arrangements apply to it, is covered under what GS1 Digital Link is and whether it is necessary for the digital product passport.
The data carrier must remain physically functional on the product
What does emerge clearly from Articles 10 and 11, however, is that the carrier — the QR code or similar code — must remain durably readable, even under normal conditions of use of the product. This is a different issue than "working offline", but they do touch: a code that is soiled, worn or damaged prevents access to the passport just as much as the lack of an internet connection. For a manufacturing company, this means that the choice of carrier, material and placement on the product is a practical consideration, separate from the question of whether the underlying data are online or offline. What to do if that code still becomes unreadable is detailed under what happens if the QR code on the product is damaged or becomes illegible.
The unique identification code must also convey something without the full passport page
Article 12 of the ESPR regulates the unique identification code that is assigned to each product. That code is itself already a data carrier: it identifies the product, regardless of whether the full passport page can be opened at that moment. For companies that handle multiple product groups, this is a reason to think through the design of that identification code carefully — not as something you sort out later, but as the basis of the entire system. How you implement that per product is described at how you give each product a unique identification code.
The register contains metadata, not the passport itself
Article 13 of the ESPR describes the register of digital product passports, in which certain data about passports are recorded so that supervision and market access can be verified. That register is a supplementary, central facility — it is not the place where the consumer or user consults the passport, and it does not replace the data carrier on the product itself. For the offline question this is relevant because the distinction between "what is in the register" and "what is visible on the passport itself" is often confused. What exactly must and should go into that register is explained at what the register of digital product passports is and what must be included in it.
Where things go wrong in practice
A few situations keep coming up with companies struggling with this question.
The assumption that a pdf on the product is "offline" sufficient. Some companies think that downloading a pdf version of the passport, which is then kept separate from the internet, meets the requirements. This is a misunderstanding of the design: the passport is intended as a living, current document that is retrieved via the data carrier, not as a snapshot that is distributed here and there.
Confusion between server availability and offline access. The question "must the passport also work if there is no wifi on the shop floor" is sometimes confused with the question "must the passport always be accessible online, anywhere". These are two different things: the first concerns the situation of the end user, the second concerns the obligation of the provider to keep the passport available.
Not accounting for a changing hosting partner. Companies that host themselves and later switch to an external party — or vice versa — run into the question of whether the data carrier will continue to work during and after that transition. This does not directly affect the offline question, but it does affect the underlying assumption that the passport must remain continuously accessible online.
Unclear coupling with internal systems. Some companies want the passport to be fed directly from their own ERP system, and then assume that that coupling must also work offline for internal use. That is a different question from the external accessibility of the passport by third parties. More on this is at linking the product passport to an ERP or inventory system.
No attention to the retention period when it comes to accessibility. The question "must it always be accessible" is sometimes separated from the question "how long must it remain so". Both belong together: accessibility without duration is just as incomplete as duration without accessibility. That subject is elaborated at how long a product passport must remain available.
What you can document
- An overview of which data carrier (QR code or equivalent) is used per product group and why.
- A description of the technical setup: which party hosts the data, and how is the reference from the data carrier to that data arranged.
- Agreements with the hosting party on the availability and continuity of the online environment.
- A procedure for what to do in case of a damaged or unreadable code on a product already on the market.
- Documentation of the unique identification code per product and the system by which it is assigned.
- An overview of which data goes into the central register versus which data only appears on the passport itself.
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 based on the sources above, reviewed by a human on 2026-09-05. Is something incorrect? Let us know — corrections are given priority.