can I make a test version of the product passport in advance
Yes, you can create a test passport before the obligation comes into force
Nothing in the ESPR prohibits practising with a product passport in advance, even for a product group that is not yet due. The regulation determines when a passport becomes mandatory and what requirements it must meet, but says nothing about what a company does voluntarily and in advance. A test passport is not a legal step in that sense, but a practical one: it is a way to discover which data are missing, which departments need to be involved, and how a QR data carrier relates to existing packaging or labelling, well before any pressure is applied.
For whom this is useful, and what it is not a replacement for
A test passport is especially useful for manufacturers and importers who know that their product group is on the schedule, but are still waiting for the delegated act that sets the precise requirements. The prioritization of product groups is set out in Article 18 of the ESPR: it specifies the criteria by which the European Commission determines which products are dealt with first, such as environmental impact and sales volume. Those in a group high on that list have more basis to test now than those in a group about which nothing is yet known.
What a test passport is not: an official document. As long as the obligation for a product group has not come into force, a test version has no legal status and cannot serve as evidence of compliance in an inspection. Nor is it a guarantee that the structure now being set up will exactly match what the final delegated act requires — it may differ on certain points. A test passport is thus a learning tool, not an advance on the obligation.
The date is not set, but testing can already begin
There is no fixed date to be given for when testing a passport "is permitted", simply because there is no rule that prohibits it or links it to a specific time. What is established is that the obligation comes into force per product group only after the European Commission has adopted a delegated act for that group, as provided for in Article 18. Until that time, no passport obligation applies to that product group, and anything a company does is voluntary — including building a test version.
This also means that the exact content of the requirements (which data, which fields, what level of detail) may still differ per product group from what is already known from the ESPR itself. A test passport built now is thus good practice in process and structure, but the content will most likely need to be updated once the final requirements for your own product group are known.
How to approach this in practice
The most logical first step is to check whether your own product group already appears somewhere in the European Commission's schedule, and if so, how far that planning has progressed. After that, it is useful to inventory which product data are already available within your own organisation — materials, origin, repair information — and which still need to be obtained from suppliers. It is often the latter that takes the most time, and a test passport shows exactly where the gaps in that chain are.
For companies that market products in multiple product groups, it is practical to start with the group that has progressed furthest in the European schedule, and then repeat the approach that results from it for other groups. If you are wondering whether this is already worth the effort for your situation, you will find an answer in the question of whether it is sensible to begin before the product group is due, and if you are looking for a structured approach, you can use the question how to tackle the product passport step by step as a guide.
A test passport is also a good opportunity to examine your own supply chain now: Article 38 of the ESPR describes which data actors in that chain — from raw material supplier to assembly company — must be able to provide once the obligation comes into effect. Whoever tests now which data are missing discovers early which suppliers are prepared for this and which are not.
The basis: Article 18, Article 22 and Article 38 of the ESPR
That the obligation is phased in per product category via a delegated act follows from Article 18 of the ESPR. That there is attention for small and medium-sized enterprises for a feasible transition is set out in Article 22, which addresses support and transition periods for that category of enterprises. And that the data for a passport must come from the entire supply chain is set out in Article 38. None of these articles prohibits or regulates voluntary testing of a passport before the obligation — and it is precisely this absence of a prohibition that forms the basis for the answer to this question.
What to do now
Anyone wishing to start with a test passport is well advised to first determine which product category their own products fall into and how far the European planning for that category has progressed, to list their own product data and those of suppliers, and on that basis to build an initial test version — knowing that it will have to be updated later once the final requirements are known. For those who first want to know whether the digital product passport applies to their own products at all, the basis for this can be found in the explanation of what a digital product passport entails.
Where this is based on
- Regulation (EU) 2024/1781 (ESPR), article 18 (prioritisation and planning)
- Regulation (EU) 2024/1781 (ESPR), Article 22 (small and medium-sized enterprises)
- Regulation (EU) 2024/1781 (ESPR), Article 38 (requirements for actors in the supply chain)
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
Making a test passport before the obligation for a product category comes into effect is not an obligation but a choice. The ESPR works with delegated regulations per product category: only when such a product category-specific regulation exists and enters into force does the actual obligation to maintain a passport arise. Article 18 of the ESPR (Regulation (EU) 2024/1781) describes how the European Commission prioritises and schedules product categories, and this means that the timing of when that obligation becomes concrete varies per product category. For an enterprise with 10 to 100 employees, this is primarily a planning matter: knowing which product category their own products fall into and how much time is realistically still available before a test version must become a real version.
Knowing when your own product category is next
In practice, this means that someone within the enterprise follows the progress of the delegated regulations, or has this followed. Without that overview, a test passport is a shot in the dark: it is then unclear whether data will actually have to be provided in a year or over several years. On Does the digital product passport apply to my products? is how that can be determined per product category.
Determining what a test version is worth
A second point is the expectation attached to testing. A test passport set up now is based on the current state of the delegated regulation or, if that does not yet exist, on the general requirements from the ESPR itself. As long as the product category-specific regulation is not yet final, the content of that test passport may still change. That is not a reason to wait, but it is a reason to treat a test passport as an exercise in process and data collection, not as a final product that remains unchanged.
Taking account of the role in the supply chain
Article 38 of the ESPR (Regulation (EU) 2024/1781) describes the requirements for actors in the supply chain, including making available information needed to compile a passport. For an enterprise that itself imports or manufactures but depends on supply chain partners for components or materials, this means that a test passport immediately shows where in the chain data are missing. This is often the most important result of a test version: not the passport itself, but the exposure of gaps in your own data management.
Assess whether your own company size changes
Article 22 of the ESPR (Regulation (EU) 2024/1781) contains provisions for small and medium-sized enterprises, for example regarding transition periods or lighter administrative burdens. For a company with 10 to 100 employees, it is important to check whether it falls within the definitions used there, as this can affect how much pressure there is now to set up a product passport and how much room there is to test first without urgency.
Where things go wrong in practice
A first scenario: a company sets up a test product passport based on a draft regulation, and when the final text is published, the mandatory data fields turn out to be organised differently in a number of respects. The test product passport was not wrong, but is treated as the final version for too long, which means that the adjustment later costs more work than necessary.
A second: the test version is created by one employee, often from marketing or quality, without involving purchasing or production. The result looks complete, but is missing precisely the data that must come from suppliers, such as material composition or repair information. Only when there is an actual delivery does it become clear that this data was never systematically requested.
A third scenario: a company tests with one product variant and incorrectly assumes that all other variants can use the same product passport. Differences in material, origin or composition between variants are then not noticed until the actual obligation takes effect. On Can I use a product passport for multiple variants of the same product is how that issue relates to the requirements per product group.
A fourth: the test product passport is seen as a one-off project, while maintaining the underlying data is an ongoing task. After the test phase, attention drops, and when the obligation actually takes effect, the information is out of date.
A fifth: testing is carried out without anyone in the company understanding well what will be asked during an inspection, so the test version looks like a product passport but does not align with what a supervisory authority will actually want to see. On What does a supervisory authority ask for during an inspection of products? is what that amounts to.
What you can document
- An overview of the product groups in which your own products fall, with the status of the associated delegated regulation.
- A list of data that are already available for a test product passport, and a list of data that still need to be requested from suppliers.
- A note on who in the company is responsible for keeping track of changes in the regulations for your own product group.
- A brief note on the status of each test version: draft version based on draft text, or draft version based on final text.
- Agreements with suppliers on the periodic provision of material and composition data, even if that is not yet mandatory.
Those who prefer to work through these steps in a fixed order will find on How do I approach the product passport for products step by step? an overview that aligns with both the prior testing and the eventual moment of mandatory compliance.
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.