what if the QR code on the product is damaged or illegible

A damaged QR code does not invalidate the product passport, but it does make it inaccessible

The product passport itself continues to exist — that is separate from the label on the product. The ESPR makes a distinction between the data carrier (the QR code, the label) and the digital product passport itself (the data that is hosted online). If the QR code becomes damaged, worn or unreadable, the data does not disappear: it remains hosted at the address where it has always been. What does disappear is the quick route to that data via a scan on the product. For the user this is a practical problem, and for the manufacturer or importer a matter that deserves attention: the passport must remain accessible throughout the entire lifetime of the product, and a damaged carrier on the product itself undermines that in practice, even if the underlying data is still in perfect order.

For whom this is relevant, and what it is not about

This concerns the physical data carrier on the product — the label, the engraved code, the sticker with the QR code — which can wear, scratch, come loose or become soiled. It is not about a product passport that is substantively incomplete or outdated: that is a different matter, with different rules on updating data. It is also not about a passport that is offline or inaccessible for technical reasons via the hosting platform itself; those who wonder whether the product passport must also be available without internetwill find a separate explanation for that. And it is not about counterfeit or misleading labels that look like a product passport QR code but are not — that is a matter of imitated labels, with its own provision in the ESPR. Here it specifically concerns: the code was correctly applied to the product, and has subsequently become physically unreadable.

No fixed date yet, but a clear line in the regulation

An exact date on which these obligations apply to a specific product group has not yet been fixed — that will be determined separately per product group via delegated acts under the ESPR. What is fixed is the principle set out in the regulation itself: the data carrier and the passport must be durable and accessible during the specified period, and that requires technical design that takes this into account. Until the first product groups actually fall under mandatory rules, there is therefore no legal clock that starts running when a label wears. But the requirement that the carrier must be durable enough to span the lifetime of the product is already part of the basic regulation and is therefore something to take into account when choosing the material and application method, well before a product group is specifically designated.

What to do about this: from prevention to repair

The first step comes before production: the choice of material and application method of the code largely determine whether wear becomes a problem. An engraved or burned-in code on a metal component will withstand differently than a paper sticker in a humid environment, and that consideration should be part of determining how the QR code is applied to the product. The second step is to ensure that the code is not the only access route: if the passport is also findable via the serial number, a unique identification code, or via the European product passport register, then a damaged sticker is an inconvenient but not an irreparable problem — the data is still there, only the quick link is missing. The third step is practically resolving a specific case: when a label on a sold product is damaged, replacement of the label is usually the appropriate way forward, with the new code referring to exactly the same passport data as the old one — so a new passport does not come into being, only a new carrier for the same passport. What is important in this regard is that each product has its own, unique identification code does not lose it with the label, so that restoring access does not mean that the product's identity must be re-established.

Basis in the ESPR: Article 11 on technical design, Articles 10 and 13 on accessibility

Article 11 of the ESPR (Regulation (EU) 2024/1781) describes the technical requirements for the design and operation of the digital product passport, including the requirement that the data carrier is durable enough for the expected lifetime of the product. Article 10 sets out the broader requirements for the passport, including the accessibility of the data during that lifetime — a requirement that is substantively separate from the physical label. Article 13 governs the register of digital product passports, in which passports are (also) retrievable independently of the carrier on the product itself. Articles 16 and 17 concern labels and the prohibition on counterfeit labels, and are relevant once the question shifts from "damaged" to "counterfeit or misleading".

What to do now

Anyone arranging a product passport is well advised to first examine the durability of the chosen carrier in relation to the product's use environment, and to ensure that the passport is also accessible via a second route than just the QR code on the product. In a specific case of a damaged label on an already sold product, replacing the label with reference to the same passport data is the usual route; anyone uncertain about the precise technical requirements for the carrier for a specific product group should consult the delegated act established for that product group, once it is available.

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

The data carrier must remain durable on the product

Article 11 of the ESPR (Regulation (EU) 2024/1781) sets requirements for the technical operation of the digital product passport, and this also applies to the physical carrier: the QR code (or other data carrier) must be resistant to what reasonably happens to the product during its lifetime. For a company with 10 to 100 employees, this means that the choice of material, placement on the product and attachment method is not a design choice, but a choice that relates to how long and under what conditions the product is used. A label that becomes unreadable within a year due to wear, moisture or UV light does not meet what is practically expected of the carrier.

The passport itself continues to exist, even if the code is broken

It is important to distinguish: the QR code is the carrier, not the passport. Article 10 of the ESPR (Regulation (EU) 2024/1781) describes the requirements for the passport as a dataset, which remains online independently of the physical carrier as long as the mandatory retention period runs. A damaged code therefore does not mean that the data has disappeared — the passport is still in place, only the access to it via the product itself is no longer usable. What is then needed is another way to access the same data, for example via the unique identification code of the product. How such a code is structured and assigned is described at how do I give each product a unique identification code.

The passport must remain findable via the register

Article 13 of the ESPR (Regulation (EU) 2024/1781) governs the register of digital product passports, into which a reference to each passport is entered. That register is relevant in the event of a damaged code, because it provides a second access route in addition to the physical carrier on the product itself. For a company, this means that registration in that register must be in order and remain in order, regardless of the condition of the label on an individual item. What exactly goes into that register and how it works is explained at what is the register of digital product passports and what must I enter in it.

The code must remain distinguishable from a look-alike

Articles 16 and 17 of the ESPR (Regulation (EU) 2024/1781) concern labels and the counterfeiting thereof. At first glance, this seems a different subject matter, but it directly affects the practice of a damaged code: if a label partially detaches, is replaced with a custom sticker, or becomes covered by another label, there is a risk that it is no longer clear which code belongs to the official product passport and which does not. For a company, this means that replacing a damaged label is not a matter of "sticking a new QR code on it", but that the replacement carrier must remain traceable to the same product passport and the same identification code.

Where things go wrong in practice

The label is cheaper material than the product itself. A QR sticker on a garden machine or outdoor furniture that is not weather-resistant, while the product itself stands outside for years. After one winter, the code can no longer be scanned, while the product is still in active use.

The code is located on a wear point. For example, on a handle, an underside that rubs along the floor, or an edge that is frequently touched. The location is technically easy to print during production, but practically the first place that becomes illegible.

There is no second access point to the product passport provided. If the only way to access the product passport is the QR code on the product, and that code becomes damaged, there is no alternative route available to the user. While the product passport with the associated data still exists.

Label replacement is carried out without establishing a link back. A service point or importer places a new label on a returned product or a product that has been repackaged, without that new carrier referring to the same identification code as the original. This creates a second, unofficial data carrier on the same product.

There is no provision for offline situations. A damaged code is not the only time when scanning does not work — a missing internet connection is also a practical problem that raises similar questions. Companies that do not view these separately often miss the fact that two different risks are at play: the carrier does not work, or the network does not work. More information on this can be found at must the product passport also be available offline without internet.

What you can document

A choice of material and fastening of the data carrier, adapted to the expected service life and conditions of use of the product group in question.
A test protocol that sets out how long and under what stress (moisture, UV, wear, cleaning) the label must remain readable, including the results of that test.
A procedure for replacing a damaged label, including how the replacement carrier is linked to the same unique identification code and the same product passport.
Documentation of the manner in which the product receives the data carrier on the product surface; further information on this can be found at how does the QR code for the product passport get on my products.
An overview of alternative access points to the product passport, such as a model number, serial number or other identification code that does not depend on the physical condition of the QR code.
A documented choice for the use of GS1 Digital Link or a comparable standard as the basis for the code, including the consideration of why that standard was chosen; further explanation can be found at what is GS1 Digital Link and do I need it for the digital product passport.
An internal process for complaint handling or return processing that specifies what happens if a customer reports that the code does not scan, and how that is resolved without placing a non-traceable replacement sticker.

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.