do I need to include information about repair and parts in the product passport
Repair information is included in most product passports, if the product group requires it
Yes, in most cases repair information will be included in the product passport, but not because that is a standalone obligation — it follows from what has been laid down for the relevant product group. The ESPR (Regulation (EU) 2024/1781) mentions repair, spare parts and maintenance as one of the categories about which the passport can contain data, alongside for example durability and recyclability. Whether that actually applies to a specific product depends on the delegated act that will be drawn up for that product group. For one product group, repair information may be a mandatory part of the passport, for another product group it may not be, or only at a more limited level.
For whom this applies and for whom it does not
This question is relevant for manufacturers and importers of products for which a delegated act under the ESPR designates repair or spare parts information as passport data. This will more often be the case for products that naturally have a longer lifespan and for which spare parts or repair play a real role, such as electronics, furniture or certain household appliances — but this is an indication, not a fixed list. It is explicitly not the case that every passport automatically receives a repair section: if the delegated act for a product group does not mention that subject, it does not belong in the passport for those products. This further concerns only information in the passport itself; other obligations regarding repair — such as possible requirements for actually making spare parts or repair services available — are a separate matter that is regulated independently of the passport and is not addressed here.
What does play a role each time is the question of which data belong in a passport anyway, regardless of the repair subject. A good overview of that general content is provided at which data will be included in the digital product passport of products; repair information is one of the possible components alongside others, such as recycling data.
No fixed date yet, but a fixed route
There is no general date on which repair information in passports becomes mandatory, because that obligation arises per product group at the moment the corresponding delegated act enters into force. Until that point, for a product group it is simply the case that there is no passport obligation yet, and therefore no obligation to include repair data. Once the European Commission adopts a delegated act for a product group, it states concretely which information categories are mandatory — and only then is it possible to say with certainty whether repair and spare parts information is included, and from when. What a delegated act actually is and why it is decisive for this type of decision is explained at what a delegated act is and why it determines what must happen. For the question of whether and when a product group will come into play, the page on when the product passport becomes mandatory for products is the point of reference.
What this means for your approach
For a manufacturer or importer preparing for this, the first step is to determine whether their own product falls under a product group for which a delegated act has been adopted or is in preparation; that explanation is provided at whether the digital product passport applies to the company's own products. If that is the case, the second step is to consult the text of that specific delegated act — not the ESPR in general terms — to see whether repair, spare parts or maintenance is actually included as a mandatory information category, and if so, in what form. This can range from a simple statement of whether spare parts are available separately to a more detailed list with repair instructions or spare parts codes.
If repair information is once designated as a mandatory passport component, the practical side follows: that data must be supplied, organised according to the structure that applies to the passport, and linked to the QR data carrier. The question of how often that data must remain current also plays a role — repair information can change if a component is replaced by a new version — and that subject is addressed in how current the data in the product passport must beAnyone who doubts whether certain repair details do not disclose too much business information will find the weighing of that issue on the page on sensitive business data in the digital product passport.
Where that is stated: Article 10 and Articles 5 to 7 of the ESPR
That the passport can contain information on repair and parts follows from Article 10 of the ESPR (Regulation (EU) 2024/1781), which sets out the requirements for the content and functioning of the digital product passport. Which information categories are made mandatory for a specific product group — which may include repair and parts — is determined via the ecodesign requirements and the related information requirements from Articles 5 to 7 of the same regulation, which form the basis for each delegated act per product group.
What to do now
Anyone wishing to know whether repair information for their own product will become mandatory should best first find out whether and when their own product group will be covered, and then consult the concrete delegated act as soon as it is available — the general text of the ESPR provides the framework, not the definitive answer per product.
Where this is based on
- Regulation (EU) 2024/1781 (ESPR), Article 10 (requirements for the digital product passport)
- Regulation (EU) 2024/1781 (ESPR), Articles 5 to 7 (ecodesign requirements, performance and information requirements)
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
Whether repair information and data on parts must be included in the passport depends on what is laid down in the delegated act for the product group in question. The ESPR itself (Regulation (EU) 2024/1781) provides in Articles 5 to 7 the basis: repair, parts, disassembly and durability are part of the ecodesign requirements that can be filled in per product group. Article 10 then determines what, if a product group receives such requirements, goes into the digital passport. For a company of 10 to 100 employees, this mainly means: finding out which delegated act applies to your own products, and working backwards from there to what needs to be organised in practical terms. What is a delegated act and why does it determine what I must do? sets out how that process works and why the content differs from product group to product group.
Determining whether repair requirements apply to the product group
The first step is to establish whether the delegated act for your own product group says anything about repair, availability of parts, disassembly sequence or repair scores. This is not a matter of reading the ESPR itself and drawing your own conclusions: the concrete obligation is in the supplementary regulation per product group. In practical terms, this means that someone within the company — often the quality or compliance manager — must follow that document as soon as it is published, and cannot rely on what applies to another product group. Does the digital product passport apply to my products? is a logical starting point to determine whether and when that obligation applies to your own products.
Making repair information available if the product group requires it
If the delegated act prescribes repair information, it usually involves matters such as: which parts are replaceable, how disassembly takes place, what tools are needed, and where repairers (professional or consumer) can turn for instructions or parts. For a medium-sized company, this means that technical documentation that often already exists internally — service manuals, parts lists, disassembly diagrams — must be made suitable for external sharing via the passport. That is a different exercise than documentation intended only for in-house technicians: the information must be understandable and findable for a broader public, and that public differs by target group. Who is allowed to view which data from the product passport? states that not every data category needs to be visible to everyone, and that there can be a distinction between what a consumer sees and what an authorised repairer or recycler is shown.
Making a distinction between repair information and recycling information
Repair information and recycling information are often lumped together in practice, but they are different data categories with different purposes: one is about keeping the product functioning, the other about what happens to it at the end of its life. For companies that must supply both, it is practical to make that distinction early in their own documentation, so that the correct data ends up in the correct section of the passport. What recycling information must I include in the product passport addresses that other part of the requirements.
Keeping the information up to date
Repair information is not static: parts are phased out, suppliers change, and service manuals are updated. For a company that hosts the passport for ten years, this means there must be an internal process that identifies and reports changes in repair documentation, even years after the first publication. How often must I update the data in the product passport? addresses what the practical expectation is for that.
Where things go wrong in practice
A first situation: a company assumes that repair information is "surely" mandatory because competitors or industry organisations talk about it, and invests time in documentation that their own delegated act does not even require — while other mandatory data receive insufficient attention.
A second situation: internal service manuals are placed in the passport unchanged, including internal company codes, supplier names or price agreements that were not intended for external use. This leads to questions about what should and should not be made public — a consideration that deserves separate attention, as described in Do I have to make business-sensitive data about my products public?.
A third situation: the repair information is supplied only in the language of the parent company, while the product is placed on the market in several member states. This only works if the requirements around language are clear, see must I offer the product passport in multiple languages.
A fourth situation: parts lists are supplied once when the passport is first set up, but are not updated when a supplier changes or a part is replaced by a new version. The passport then shows an outdated list for ten years.
A fifth situation: an error in the disassembly instruction or part number is only discovered after the passport is already online, and nobody within the company knows which route to follow to correct it. For that, see I have discovered an error in a product passport that is already online what now.
What you can document
- The delegated act(s) applicable to your own product groups, with a note on whether repair or parts requirements are included.
- An overview of existing internal documentation (service manuals, parts lists, disassembly diagrams) that may need to be adapted for the passport.
- A list of data that are technically relevant but not intended for external use, with a decision on who may view this.
- A person responsible or team that identifies and reports changes in repair information (new parts, changed suppliers) for updating the passport.
- A template or fixed structure for how repair information is supplied, so that each product group is documented in the same way.
- An overview of which data from What data goes into the product passport for products? are already available and which are still missing for your own product group.
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.