what information about recycling must I include in the product passport

Recycling information follows from the product group, not from a fixed list

There is no general checklist with "the" recycling information that must be included in every product passport. The ESPR (Regulation (EU) 2024/1781) states in Article 10 what a product passport must be able to contain in general terms and how it must work technically, but which recycling data are concretely mandatory is laid down per product group in the information requirements that will apply to that group under Articles 5 to 7. For one product group this may concern the percentage of recycled material, for another it may concern disassembly instructions or the presence of substances that complicate recycling. Without the established requirements for a specific product group, there is no fixed content to be identified.

For which products this is already established, and for which it is not

This approach applies to all product groups that will fall under the ESPR — from textiles to furniture to electronics — but each time only after the delegated regulation has been established for that specific group. For a product group for which that regulation does not yet exist, there is also no concrete recycling obligation for the passport. It is therefore important first to establish whether the product passport already applies to the specific product, before looking at recycling details. It is also important to distinguish from other parts of the passport: recycling information is separate from repair data — that is a different matter, see information about repair and spare parts — and separate from the question of which party may access which data, which is a separate regulation.

Only concretely once the delegated act for the product group exists

There is no fixed date on which "the" recycling obligation takes effect, because that date differs per product group and per delegated act that the European Commission establishes for it. Until such an act exists for a specific product group, no obligation applies to that group to include recycling information in the passport — the ESPR itself lays down the framework in Article 10, but the substantive implementation follows only with the product group-specific rules under Articles 5 to 7. Anyone who wants to know when this will apply to a concrete product group will find the current status summarised on the page about when the passport becomes mandatory.

How to approach this in practice

The investigation starts with the product group, not with the passport. First, it is relevant whether a delegated act has already been established or is in preparation for your own product — this specifies exactly which recycling data are requested, such as the share of recycled material, the recyclability of components, the presence of substances that disrupt recycling, or instructions for disassembly at the end of life. Next, it is important to determine who in your own company has that data: such knowledge often sits in procurement or engineering, not in the department that compiles the passport. This is followed by the question of how those values were determined — this relates to the measurement method prescribed for the product group, see the explanation about how the values for the passport must be measured. Only when these three points are clear — which data, from whom, and according to which method measured — can the passport actually be completed. For the full set of what else belongs in a passport besides recycling, the overview of the data in the product passport provides a complete picture, so that recycling information is not treated separately from the rest.

A practical point here: recycling data sometimes change after production, for example when a component supplier changes or a test result is revised. How this is handled during the lifetime of a passport is described in the answer to the question how up-to-date the data in the passport must remain. And if it subsequently emerges that a recycling value is incorrect in a passport that is already online, there is a separate process for correction, which can be found at correcting an error in a published passport.

Where this is set out: Article 10 and Articles 5 to 7 of the ESPR

Article 10 of the ESPR (Regulation (EU) 2024/1781) sets out the general requirements that a digital product passport must meet — the technical structure, accessibility and the manner in which information must be recorded. However, the substantive question of which recycling information is concretely required follows from the product group-specific ecodesign requirements that are established pursuant to Articles 5 to 7 of the ESPR. Those articles provide the framework for the performance and information requirements per product group, within which recycling is one of the possible topics, alongside for example sustainability, repairability or the use of hazardous substances.

For those wishing to get started now: begin by establishing whether a delegated act has already been published or is under consultation for your own product group, and in the meantime collect the recycling-related data that is already known within the company — share of recycled material, material composition, disassembly information — so that completion of the passport does not suffer delay once the obligation for that product group takes effect.

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 ESPR is a framework regulation: Article 7 mentions recycling and material use as a category on which information or performance requirements can be set, but which recycling data must precisely appear in the passport of a particular product group is determined per product group via a delegated act. What is set out below is therefore the pattern that emerges from Article 7 and Article 10 of the ESPR, not an exhaustive list that is the same for each product.

Information on recycled content

Article 7 mentions the share of recycled material in a product as one of the aspects on which requirements can be set. For a company with 10 to 100 employees this means in practice that the composition of the material used must be traceable down to raw material level: which part of a plastic component for example comes from recycled granulate, and which part from virgin material. That information usually comes from the supplier of the raw material or semi-finished product, not from your own production data, which means that a link in the chain is engaged here that was never previously asked for this kind of figures.

Information on the product's own recyclability

Alongside the share of recycled material in the product, the question is also what can happen to it after use: what materials the product is made of, how those materials are joined together (glued, welded, screwed) and whether components can be separated for recycling. This touches on what a product designer already knows, but that knowledge is often not recorded anywhere — it sits in the heads of the people who designed the product, not in a document that can be transferred to a passport.

Information on hazardous substances that affect recycling

Article 7 also links material information to substances that can disrupt or render unsafe the recycling process. This overlaps with information that is already kept for other purposes (REACH compliance, safety data sheets), but must for the passport be put in a form that says something about the impact on recycling specifically, not only about hazard to the user.

Instructions for disassembly and processing at end of life

Where Article 7 speaks of preparation for recycling, this may also mean that instructions must be provided on how to disassemble a product at the end of its life — which components must be processed separately, what matters in terms of valuable materials worth the effort of sorting. For many companies, this is a document that does not yet exist, because until now there has been no reason to draw up such an instruction apart from internal production documentation.

Link to what is already recorded for repair

Recycling information does not stand alone from other lifetime information. What is recorded about disassembly and material separation often overlaps with what is also needed for repair and spare parts in the passport : someone who takes a product apart to repair it uses similar knowledge as someone who disassembles it at the end of its life for recycling. It is more efficient to map these two together than separately twice.

Where things go wrong in practice

The recycled content is estimated rather than substantiated. A company knows approximately what percentage of recycled material is in a raw material, but has no document from the supplier confirming this. Once this estimate is in the passport, a claim has been made that cannot be substantiated if ever questioned.

Design knowledge about disassembly does not exist on paper. The person who designed the product knows exactly how to take it apart, but no one has ever recorded this because it was not previously necessary. When the passport needs to be completed, this information turns out to exist as knowledge, not as a document — and that knowledge is not always still available by the time it is needed.

Material information from suppliers is missing or incomplete. An importer obtaining products from a manufacturer outside the EU discovers that the supplier does not provide a detailed statement of material composition, only a general description. Without that statement, there is no basis for putting recycling information in the passport that is correct.

Recycling information is confused with environmental claims that are regulated separately. Statements such as "100% recyclable" on packaging fall under different rules than the structured data that must come in the passport. Confusing these two together leads to a passport that contains marketing language instead of verifiable data.

No distinction is made between what may be public and what may not. Some information on material composition relates to the formula or composition of a product, which may be reason to review what is established in the product passport regarding commercially sensitive data , instead of making everything public without thought.

What you can document

An overview of material composition per product, with per material the share of recycled and new material, substantiated with documentation from the supplier
Declarations or certificates from suppliers regarding recycled content in supplied raw materials or semi-finished products
A design document recording how the product is structured (connections, materials, components) with disassembly in mind
A disassembly instruction for processors at the end of life, including which components must be processed separately
An overview of substances in the product that are relevant to the recycling process, linked to existing REACH or safety documentation
An agreement with suppliers on which material data are to be provided as standard with new orders, so this does not have to be sorted out each time

Which of these points will actually be mandatory for a specific product category will only be determined once the corresponding delegated act has been published; until then, this overview is a starting point to begin documenting what is already known about materials and disassembly instead of waiting until the requirements are established. More information about the data that will be included in the passport is described in which data are included in the product passport.

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.