What is a digital product passport for products?
A digital dossier with the product, accessed via a data carrier
A digital product passport is a collection of digital data about a specific product, accessible via a data carrier on or with that product — usually a QR code. The passport contains information relevant to the entire life cycle of the product: what it is made of, how to repair it, which substances it contains, how it can be recycled, and data demonstrating that the product complies with the requirements applicable to that product group. The idea behind the passport is that this information is no longer scattered across separate documents, certificates and packaging texts, but is digitally available in one place for those who need to work with it: the consumer who wants to know what he is buying, the repair technician who is looking for spare parts, the recycler who wants to separate materials, and the enforcement authority who checks whether a product complies with the rules. The passport itself is not a quality mark and not a guarantee — it is an information carrier, compiled from data supplied by the manufacturer or importer.
Not for every product, but for designated product groups
The obligation to maintain a digital product passport does not automatically apply to all products placed on the market in the EU. The ESPR (Regulation (EU) 2024/1781) is a framework regulation: Article 9 describes what a digital product passport is and when it becomes mandatory, and Article 10 describes what a passport must meet if it is introduced. Whether a product group actually needs a passport is determined separately for each product group in a delegated act. This means that in practice the obligation is introduced step by step, product group by product group, and not all at once for all products. For a manufacturer or importer, the first question is therefore not 'does the ESPR apply to me', but 'is there a delegated act for my product group that makes the passport mandatory, and what exactly does it require'. As long as there is none, the requirements of Articles 9 and 10 do not yet apply concretely to that product.
When it comes into force, it is determined per product group
There is no fixed date on which the digital product passport comes into force all at once for all products. The ESPR itself sets out the framework, but the moment when a specific product group actually has to get started is set out in the delegated act established for that product group. For one product group that moment may be nearer than for another, and for many product groups no delegated act has yet been established. What is certain is the structure: Articles 9 and 10 describe the form and content that a passport must have as soon as it becomes mandatory, so that manufacturers can prepare for it even before the obligation applies to their product group.
From checking whether it applies to linking it to the QR code
For a manufacturer or importer with products in multiple product groups, this topic involves several steps. First, you need to determine whether a delegated act has already been adopted for a product group that makes the digital product passport mandatory — this varies by product group and changes over time. Next comes the data: what information must be included in the passport according to that delegated act, combined with the general requirements in Article 10, such as a unique product identification and the way different users (consumer, competent authority, recycler) gain access to different parts of the information. Subsequently, that information must be recorded in a passport that meets the technical requirements — interoperable, capable of being linked to a data carrier, and available for the required period. For a company with multiple product groups, this often means that the passport has slightly different content per product group, while the process of submitting, hosting and linking to a QR code can remain the same. Prodpas.eu compiles the passport from the data supplied by a manufacturer or importer, hosts the passport for ten years, and supplies the QR code as a data carrier — so that process does not need to be reinvented for each product group.
Legal basis: Articles 9 and 10 of the ESPR
All of this follows directly from the ESPR (Regulation (EU) 2024/1781). Article 9 introduces the digital product passport as an instrument and regulates the conditions under which it becomes mandatory for a product group. Article 10 specifies what a passport must comply with: from the way it is accessible via a data carrier to the requirements for interoperability and access to data for different parties. The precise content and date of implementation for a specific product group are not set out in these two articles themselves, but in the delegated act adopted for that product group — that act is therefore the source to monitor once it is available.
Anyone who wants to know whether this applies to their own product group should best check whether a delegated act under the ESPR has been adopted or is being prepared for that group, and consult the text of Articles 9 and 10 to see what requirements are already established there. For those who want to prepare in advance for when the time comes, collecting product data — composition, origin, repair and recycling information — is a step that does not need to wait for the final date.
Where this is based on
- Regulation (EU) 2024/1781 (ESPR), article 9 (digital product passport)
- Regulation (EU) 2024/1781 (ESPR), Article 10 (requirements for the digital product passport)
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
A digital product passport is, in short, a dataset about a product that can be requested by anyone in the chain via a data carrier — usually a QR code. Article 9 of the ESPR (Regulation (EU) 2024/1781) establishes that the passport is linked to a specific product or product model, and that the data contained in it must be verifiable and up to date. Article 10 sets out the technical and organisational requirements that the passport and the data carrier must meet. For a company with 10 to 100 employees, this amounts to a number of separate, but interconnected, obligations.
Creating and maintaining one passport per product
The passport is not a brochure that you write once and leave as is. It is a dataset that must remain accurate with the product as it is actually on the market. If a component, a material or a test result changes, then in principle the content of the passport also changes. For a company with a limited number of product lines, this means that there must be a fixed moment in the process when someone checks whether the passport still matches reality — not as a separate action afterwards, but as part of the normal product modification or revision.
Ensuring that the data carrier is placed on or with the product
Article 10 sets requirements for the data carrier itself: it must be physically durable, remain legible throughout the period that the product is in use, and be located in a fixed, easy-to-find place. For many companies, this is a practical production issue: is the QR code printed on the packaging, attached as a label, or engraved in the product? Whoever arranges this process must also account for what happens if the packaging is thrown away or the label comes off — the carrier must remain practical in practice, not just at the moment of sale.
Keeping the correct data available for the correct parties
Not all information in the passport is visible to everyone. A consumer sees different data than a market surveillance authority or a recycler. Article 10 regulates this distinction in access levels. For a company, this means that the underlying data infrastructure — where the data comes from and who is allowed to see it — must be clearly organised, which in practice often coincides with the choice for a hosting party that already supports this rights structure. Which data are exactly mandatory varies greatly by product group; which data goes into the product passport of products goes deeper into this.
Aligning the passport with the correct product group requirements
The ESPR itself mentions in Articles 9 and 10 the general structure of the passport, but the concrete content — which data, which thresholds, which test methods — is determined separately for each product group. This does not happen in the regulation itself, but in a delegated act per product group. Without that delegated act, there is no passport obligation for a specific product yet, even if the ESPR is already in force. How that elaboration works exactly is explained on what is a delegated act and why does it determine what I must do.
Taking into account multiple passports per product
Some products consist of components that are themselves subject to a separate passport obligation — a battery in a device is the most well-known example of this. This can mean that one end product has to deal with multiple passports, each with their own source data and administrator. This applies especially to composite products, about which my product falls into multiple product groups — what does that mean more explains.
Where things go wrong in practice
A passport is created when a product is launched and is not updated thereafter, while in the meantime the supplier of a raw material has changed. The QR code is printed on a sticker that becomes unreadable after a few months of use, so the data carrier exists but no longer functions as intended. A company thinks the passport is only relevant for the end product and forgets that a purchased component — such as a battery — may have its own passport obligation that is separate from that of the end product. It is assumed that "digital product passport" is a fixed, uniform dataset that looks the same for every product, whereas the content varies greatly by product group and is only finalized once the corresponding delegated act is in place. And a company assumes that because the ESPR "applies to all products", every product must have a passport immediately, whereas the actual obligation enters into force by product group in a phased manner — see when does the product passport become mandatory for products for how that phasing works.
What you can document
- An overview of which products or product groups in the company fall (or may fall) under the ESPR, including components that may require their own passport
- A fixed control moment in the product modification process to check whether the passport is still current
- Documentation of the chosen data carrier (material, placement, expected lifespan of the QR code or chip) and the reason for that choice
- An overview of who may view or edit which data in the passport, including agreements with suppliers on the delivery of source data
- A list of sources for each product data point — where does each figure or claim in the passport come from, and who is responsible for it
- References to the delegated act that applies to the company's own product group, so it is clear which version of the requirements is being followed
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.