How does the QR code for the digital product passport get onto my products?

Manufacturer or importer places the QR code themselves

The QR code does not automatically end up on the product: the manufacturer or importer applies it to the product itself, the packaging, or the accompanying documentation. The platform that compiles and hosts the digital product passport supplies the data carrier — the QR code that refers to the passport — but applying it to the physical product is an action that lies with the manufacturer or importer. The QR code must be linked to a unique product identification, so that each passport belongs to the correct product, and must be readable without requiring special, proprietary equipment.

For products subject to the product passport requirement

This approach applies to product categories for which a digital product passport becomes mandatory, as determined per product category in an implementing regulation under the ESPR. It does not automatically apply to every product a company places on the market — only to product categories for which such an obligation has actually been established. It is also important to distinguish this from the energy label: that is a different instrument, with its own rules from Article 16 of the ESPR, and in some cases may exist together with or alongside the product passport. The QR code of the product passport itself falls under Article 11 and is a separate technical requirement, independent of whether a product also carries an energy label.

Placement rules differ by product category, and the date is not fixed everywhere

When and how the QR code must be applied exactly varies by product category. The ESPR itself sets out the general technical requirements in Article 11 — durability of the data carrier, linking to a unique identification number, accessibility without proprietary technology — but the concrete details, such as the exact location on the product or the minimum size, are worked out per product category in an implementing regulation. For many product categories, this elaboration has not yet been established. Until a product category has such a specific regulation, there is no concrete obligation for that category to apply a QR code. What is already established is the generic framework from Article 11: the requirements that a data carrier must meet one way or another once the obligation comes into force for a product category.

From passport data to QR code on the product

The sequence in which this typically proceeds begins with determining whether and when the product category falls under a product passport requirement — that information comes from the implementing regulation for that specific category. Subsequently, the product data is submitted to the platform that compiles the passport; based on this, the passport is hosted and the corresponding QR code is generated, linked to the unique product identification. That QR code is then physically applied to the product, packaging, or documentation, depending on what has been established for the product category. It is important that the code remains durable and readable during the period in which the passport must be available, and that the code cannot be confused with another label. Article 17 of the ESPR prohibits counterfeiting of labels in a way that could cause confusion about origin or meaning — a consideration that also applies when designing and placing a proprietary QR code or sticker alongside the passport. Anyone wishing to place an additional sticker or code on the product should therefore ensure that it is clearly distinguished from the official product passport QR code and from existing labels such as the energy label.

The basis: Article 11, 16 and 17 ESPR

The technical requirements for the QR code as a data carrier — durability, linking to a unique identification, accessibility without proprietary technology — follow from Article 11 of Regulation (EU) 2024/1781 (ESPR). The distinction between the product passport and the energy label, and the possibility that both can exist side by side, follows from Article 16 of that same regulation. The prohibition on imitating labels in a way that causes confusion is set out in Article 17. The exact placement rules per product category — where the code must be placed exactly, in which format — are each worked out in the implementing regulation established for that product category, and are therefore not found in the ESPR itself.

If you want to know whether your products are already subject to such an obligation, it is best to check this for your own product category, since this differs per category and has not yet been established everywhere. Once that is known, the next step is to submit the product data, so that the passport and the associated QR code can be compiled and hosted — after which affixing it to the product is the final step that lies with the manufacturer or importer itself.

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 be on the product, packaging or documentation

Article 11 of the ESPR (Regulation (EU) 2024/1781) requires that the digital product passport is accessible via a data carrier — in practice usually a QR code. Where exactly that code must be placed (on the product itself, on the label, on the packaging or in accompanying documentation) is determined per product group in the delegated act for that group. For a company with 10 to 100 employees, this means that the placement of the code becomes part of the production process or packaging line, not something that is solved afterwards with a sticker. Companies that supply multiple product groups will quickly encounter multiple variants here: one product gets the code on a nameplate, another on the box. If a product consists of multiple parts that each receive their own passport, it is worthwhile to determine in advance whether each part receives its own passport or the product as a whole, because that also determines how many codes must be physically applied.

The code must lead to the correct, current data

Article 11 sets requirements for the functioning of the passport: the data carrier must point to the passport that belongs to that specific product, and that passport must display the data that is mandatory for that product group. This seems self-evident, but becomes technically concrete only once it is clear how a product obtains its unique identity. Without a good system to assign each product a unique identification code it is impossible to guarantee that scan number 4,582 from a production line points to precisely that passport and not to another copy of the same series. For companies working with batches, variants or series production, this is one of the most underestimated parts of the process.

The code must continue to work, even after sale

Article 11 links to the passport a requirement of sustainable availability: the data must remain retrievable, even after the product has been sold and changed ownership. This affects not only the hosting side, but also the physical code itself. A QR code that fades, comes loose or becomes unreadable through wear undermines that availability just as much as a server that is offline. For a company that delivers products in the open air, in workshops or in intensive use, the choice of material and application method is therefore not an aesthetic matter but one that is directly linked to this obligation.

The code must not be confused with a certification mark or label

Articles 16 and 17 of the ESPR deal with labels and the prohibition on counterfeit labels. This is relevant for the QR code, because some companies want to combine the data carrier with existing graphic material — an energy label, their own quality mark, a logo. The rules around labels are intended to prevent confusion about what an official label is and what is not. For practice, this means that the QR code is treated as a separate, recognizable carrier and is not simply embedded in an existing label design without making clear which element stands for what.

Where things go wrong in practice

The code is incorporated too late in the design process. Packaging and product labels are determined months before production starts by the marketing or packaging department. If the QR code must then be added, it becomes too small, stuck on a curve where it does not scan, or printed across a seam.

One code for an entire batch, instead of a unique code per product. This works until there is a recall, warranty claim or inquiry from an enforcement authority about one specific item — then it turns out that all passports are identical and no one can prove which passport belongs to which physical product.

The code points to a page that the company manages itself without standard structure. Without using a standardized link, as discussed at GS1 Digital Link, a patchwork of individual URLs per product line emerges, which is difficult to maintain and does not align with what buyers, supervisors or platforms expect.

No one has given thought to wear or damage. A code that becomes unreadable within a year due to UV light, moisture or use undermines the obligation under article 11 that the data remains accessible. What happens in practice then is described at a damaged or unreadable QR code.

The code is managed separately from the ERP or inventory system. If creating the unique code and linking it to the passport is a manual step performed by someone in the packaging department, the risk of errors and backlogs is considerable. This is particularly problematic for companies that want to investigate whether the passport can be linked to their own ERP or inventory system, but are only considering that step after the first batches have already been produced.

What you can document

An overview per product group of where the QR code is physically applied (product, label, packaging or documentation), including the reason for that choice.
The method by which each production unit receives a unique identification code, and who within the company is responsible for generating and checking it.
Specifications of the material and application method of the code, tailored to the expected use conditions of the product (outdoor, intensive use, exposure to moisture or chemicals).
A test procedure: how and how often is a sample of produced codes checked to ensure they actually scan and lead to the correct passport.
A documented agreement on what happens if a code is damaged before sale (in the factory or warehouse) versus after sale with the end user.
Documentation of the link between the passport system and any other company systems, so that in the event of staff changes or audit it is clear how the data flow runs.
An overview of which products fall under multiple passports and how that relates to the physical application of codes, relevant when multiple passports for one product come together on the same item.

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.