how do I prepare my staff for working with the product passport

Multiple departments are involved, not just quality

The product passport is not a separate IT project but a collection of obligations that runs across the organization, and that means that preparation is more than having one employee click through a system. Procurement must obtain data from suppliers, quality or compliance must know which information is mandatory according to article 10 of the ESPR (Regulation (EU) 2024/1781), production or engineering must know what needs to be reported about the product itself, and customer service or returns will at some point receive questions from customers who scan the QR code and do not understand something. Whoever treats the passport as a task that comes "on top of" other work runs the risk that preparation stalls with one person who does not have all the information in-house — and that is precisely where things often go wrong.

This concerns preparation for the process, not legal training

This explanation is about practically preparing a team: who does what, which data must come from where, and who is the point of contact if something goes wrong. It is not about providing a course in European law to everyone involved with the passport — that is not necessary for most roles and would not be useful either. It is also not about whether a specific product already falls under the rules; that is determined separately per product group and that question is answered on the page about whether the digital product passport applies to specific products. Team preparation is therefore an organizational matter, not a legal one — although the organization will of course touch on what the law requires.

The sequence is fixed per product group, the timing for your team is not

When a product passport becomes mandatory differs per product group: that is determined through work plans and delegated acts as described in article 18 of the ESPR, which covers prioritization and planning of product groups. For most product groups the precise date is not yet set at the moment a manufacturer begins to prepare, and that is also no reason to wait. Until the obligation becomes effective for a specific product group nothing changes for the team in what is legally required — but the time needed to get data in order, link systems and familiarize colleagues is separate from that legal date. Whoever waits until the date is set starts with less time than someone who begins earlier; that idea is further developed on the page about whether it makes sense to begin before a product group is due.

How to approach team preparation

The first step is to appoint one owner of the subject within the organization — not necessarily someone who executes everything themselves, but someone who maintains an overview of who supplies which piece of data. Next follows an inventory: which product groups does the organization have, which information about them is already available (technical specifications, material composition, origin of components, repair and recycling information), and who within the company or at a supplier has that information. This aligns with article 38 of the ESPR, which sets requirements for actors in the supply chain — meaning that preparation often does not stop at the organization itself but also requires contact with suppliers about what they must deliver and when.

Subsequently it is useful to determine who on the work floor will be involved with the passport: someone who compiles or submits the passport, someone who verifies the data is correct before publication, and someone who responds if a supervisory authority or customer asks questions. For that last role it is helpful to know in advance what a supervisory authority can actually ask during an inspection, so that an employee is not confronted with that question for the first time when an inspector arrives; that is described on the page about what a supervisor asks during an inspection. After that, it is advisable to practise with an unofficial version of the product passport, so that the team experiences how it works before anything becomes mandatory; how that works is described on the page about creating a test version in advance. Anyone who markets multiple variants of the same product should also immediately clarify how this is handled with one passport or with multiple passports, as this directly affects the way data is organised — see the page about one passport for multiple product variants. Finally, it is recommended to make clear within the team what the passport delivers besides an obligation, so that the preparation is not experienced only as a burden; this is explained on the page about what a passport delivers.

The legal basis: Articles 9, 10, 18 and 38 of the ESPR

The obligation to have a digital product passport follows from Article 9 of the ESPR (Regulation (EU) 2024/1781), and the substantive requirements that the passport must meet are set out in Article 10. Which product category is required when is governed by the prioritisation in Article 18, and the obligations that apply specifically to actors in the supply chain — manufacturers, importers, distributors — follow from Article 38. Together, these articles do not determine how a team is prepared, but they do determine which tasks ultimately fall to whom, and thus also who within an organisation needs to know in time what is expected of them.

Anyone who wants to start preparing their team now should begin by inventorying product categories and available data, and from there work through the steps described on the page about tackling the product passport step by step.

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

The product passport is not a form that is filled in once and then put away. It is a data flow that runs from procurement to quality to sales to customer service, and at each of those points there are people who need to know something, need to fill in something or need to explain something. Anyone who treats the passport only as an IT project or as a legal project will sooner or later discover that practice does not follow that division.

What is expected of you

Providing data correctly and up to date

Article 9 of the ESPR (Regulation (EU) 2024/1781) provides that the digital product passport contains the prescribed information and is accessible via the data carrier on the product. That information does not come out of nowhere: someone in the organisation enters it, checks it, or provides it to a service provider. For a company with 10 to 100 employees, this usually means that procurement, quality or product management provides the source data — materials, origin, test results, repair information — and that someone else converts that data into the passport itself. If no one knows who that 'someone else' is, the task will remain undone until someone happens to notice it.

Ensuring that the passport meets the correct requirements

Article 10 of the ESPR (Regulation (EU) 2024/1781) describes the technical and functional requirements that the digital product passport must meet, such as linking to a unique identification code and accessibility via the data carrier. This does not only affect the person who creates the content, but also whoever tests the passport before the product leaves the building. In practice, this is often a task that falls between quality and logistics: who checks that the QR code on the box actually leads to the correct passport, and who does that for a new product variant?

Know when which product category is required

Article 18 of the ESPR (Regulation (EU) 2024/1781) concerns the prioritisation and planning of product categories: not everything will become mandatory at the same time. For a company active in multiple product categories, this means that different teams must get to work at different moments. Those who do not track this centrally run the risk that product category A is already well prepared while product category B has not yet started, simply because no one kept the overview. Does the digital product passport apply to my products? is a question that therefore is not answered once, but anew per product category.

Sharing and receiving data with and from the supply chain

Article 38 of the ESPR (Regulation (EU) 2024/1781) describes requirements for actors in the supply chain, which means that a manufacturer or importer is often dependent on suppliers for part of the source data. For the team, this means that procurement takes on a role that goes beyond price and delivery time: material composition, origin or other passport data must also be requested, and that conversation must be conducted by someone who knows why that question is relevant.

Where things go wrong in practice

A commonly seen pattern is that responsibility is placed with "IT" because the passport is digital, while IT does not have the source data and does not know which repair information is relevant for a specific product. The passport then remains technically sound, but substantively empty or outdated.

A second situation is that the quality department provides data for the passport of the main product, but not for the variants that follow afterwards. With can I use a product passport for multiple variants of the same product it becomes apparent that a variant cannot automatically reuse the same passport once materials or properties differ — and that is precisely the moment when a team without clear agreement leaves a gap.

A third: customer service receives questions about the passport — why is this in it, why is that missing — but has never been briefed on what the passport does and does not do. This leads to answers that are incorrect or to a question that remains circulating internally without an owner.

A fourth situation occurs with the takeover of existing stock or with old product lines: someone on the shop floor assumes that old stock does not need a passport, whereas what do I do with stock of products that are already there when the rules come into force makes clear that this is not simply an assumption that can be made without checking.

A fifth: no one on the team is designated to respond if a supervisor visits. What does a supervisory authority ask for during an inspection of products? makes clear that this conversation should not be improvised — and that requires someone who knows in advance which documents are where.

What you can document

An overview of who provides which source data, per product category: procurement, quality, R&D, or an external supplier.
A designated owner per product category who tracks the passport and the associated planning, especially with regard to the phased implementation that follows from Article 18 of the ESPR.
A fixed procedure for new product variants, so that it is clear who determines whether an existing passport can be reused or not.
A brief instruction for customer service and sales about what the passport contains, where the QR code points to and who handles substantive questions.
Agreements with suppliers on which data they provide and in what form, in line with Article 38 of the ESPR.
A test moment before going live, whereby it is checked whether the data carrier points to the correct passport; can I make a test version of the product passport in advance describes what that looks like in practice.
A file per product group with the underlying source documents, so that a check does not lead to searching but to providing.

For companies that do not yet know where to start, How do I approach the product passport for products step by step? provides an order that can serve as a basis for internal task allocation — often that is a more convenient starting point than immediately placing the passport as one large project with one department.

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.