What does a product passport deliver besides being mandatory?

More than one obligation to tick off

A product passport primarily provides clarity: one place where product information is correct, up to date and can be used by different parties, instead of having to search for and send the same data repeatedly. For a manufacturer or importer, this means technical documentation, test results and declarations that already exist are bundled and structured in an accessible way. A customer, a repairer, a recycling company or a supervisor can consult the same source via the QR code, without needing to make a separate request each time. This not only saves time on inquiries that would otherwise come in by email or phone, it also provides a fixed reference of what was precisely communicated about a product at the time it was placed on the market — something you can fall back on later, in case of a dispute or an inspection.

What the passport does not automatically deliver is a marketing advantage or a guarantee of increased sales. It is not a quality mark and it does not replace other mandatory declarations, such as CE marking or a safety data sheet. The benefit lies in the efficiency of information exchange within the supply chain, not in an additional sales argument that works independently.

For product groups with a delegated act, not automatically for everything

This benefit applies to products that fall under a product group for which the European Commission has established ecological design requirements and a passport requirement via a delegated act, as referred to in the ESPR (Regulation (EU) 2024/1781). The regulation itself provides the framework; the actual obligation — and thus also the practical utility of the passport for a specific product group — only arises once that product group has been specifically designated. For products outside such a designated group, there is no passport requirement and therefore no structured data benefit that comes with it.

Even within a designated product group, the benefit is not equally great for every party. A product with a long lifespan, many components and a chain of repairers and recyclers benefits more from a centrally accessible file than a simple product that is rarely repaired or dismantled. The basic obligation is the same for both, but the practical benefit — fewer repeated requests, less separate documentation — increases as more parties in the supply chain actually work with the data.

No fixed start date yet, but a fixed structure

There is no general entry date for 'the product passport', and there will not be one — each product group will have its own timeline via a separate delegated act under the ESPR. At the time of writing, such an act has not yet been established for every product group, and where it has, the date on which the obligation comes into force varies per group. As long as no delegated act with a passport requirement has been established for a product group, no obligation applies to that group and therefore no reason to introduce a passport now. What is established is the structure set out in Article 9 of the ESPR: what a digital product passport must contain in any case and how it must be accessible, once the obligation for a product group comes into force.

What this concretely means, in the order to approach it

First, check whether, and if so when, your own product category falls or will fall under a delegated act with passport requirements — this determines whether the rest is relevant. Next, it is useful to inventory what data already exists: technical files, test reports, declarations of conformity, warranty and repair information. Much of what a passport needs often already exists, but is scattered across different departments or systems. Then it is worth looking at which parties in your own supply chain — customer service, repairers, distributors, recycling partners — are already asking questions that would be automatically answered by an accessible file; this shows where time savings are greatest. This is followed by the question of how to integrate such a passport with existing systems, such as an ERP package or quality file, so that data is not duplicated. Those who start early avoid having to build a reliable dataset under time pressure as soon as an obligation for their own product category becomes concrete — and the benefit of a passport only materializes when the data is correct and kept current, not at first publication.

Where this is stated: Article 9 ESPR

What a digital product passport must contain and what purpose it serves — accessible, reliable product information for parties in the value chain and for supervisory authorities — follows from Article 9 of the ESPR (Regulation (EU) 2024/1781). The broader background, why the European Commission links this obligation to circular use of products, is explained on the European Commission's page on the regulation for ecodesign of sustainable products.

What to do now

Those who want to know if this will apply to their own assortment check via the European Commission's page which product categories have already been designated or are in preparation, and then monitor the delegated act for their product category for the precise content and entry into force date. Until then, it is mainly useful to get your own product data in order — not because it is already required, but because that is the step that will take the most time later.

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

The digital product passport is usually discussed as an obligation: Article 9 of the ESPR (Regulation (EU) 2024/1781) specifies what information it must contain, and the rest of the regulation determines which product groups it applies to. That is the binding side. But a company that treats the passport only as a burden is missing out. The same data collection that becomes mandatory is also simply business information — about its own suppliers, its own materials, its own production line — that can be used for other purposes.

What is expected of you

Recording data on materials and composition

The regulation requires information on the materials, components and substances in a product, insofar as relevant for the product group in question. For a company with 10 to 100 employees, this means in practice that someone — often procurement or engineering — must ask all suppliers about what exactly is in a product. That work is valuable in itself: companies that carry out this inventory regularly discover where they have duplicate suppliers, where material specifications are outdated, or where a cheaper alternative is available that no one considered before because the composition was never systematically documented.

Including information on repair and maintenance

For products where repair is relevant, Article 9 expects information on disassembly, parts and maintenance. This forces a company to document what has so far often existed only in the head of a service technician. This documentation is useful for the company's own customer service, for distributors who offer maintenance themselves, and for drawing up clear repair instructions that may currently be missing or scattered across different documents.

Demonstrating product origin and traceability

A passport links data to a specific product or product model, identifiable via the QR data carrier. For a mid-sized company, this means there must be a system that makes a product, or a batch of products, traceable to the raw materials used and the production process. Once a company has that system in place, it can also use it in a recall, in response to a complaint about a specific batch, or in response to a question from a major customer who must themselves demonstrate where their supply chain comes from.

Keeping information available for the entire lifetime

The regulation requires that the data in the passport remain accessible, even after the product is sold. In practical terms, this requires a hosting solution that does not depend on the continued existence of a single web page on the company's own site. Companies that have invested in this once have also built up an archive of all product versions they have ever brought to market — something that legal departments and warranty departments often wish they had.

Where things go wrong in practice

A number of situations come up repeatedly with companies that are working with the passport:

Data scattered across too many departments. Procurement knows the materials, engineering knows the repair instructions, marketing knows the packaging information — but no one has the overview. The passport forces that information to be brought together, and that bringing together often turns out to be the biggest bottleneck, not the technology of the QR code itself.
Suppliers who do not themselves know what is in their material. Especially with companies that have international supply chains, it takes longer than expected to find out about composition and origin, because the supplier's supplier must also be asked.
One passport per wrong unit. Some companies create a new passport for each unit sold, whereas a product passport for multiple variants of the same product often suffices and entails much less management burden.
Waiting until their own product group is "called up". Companies that leave everything until the obligation becomes concrete discover that the data inventory alone takes more time than expected — while starting before their own product group is due provides precisely that advantage of avoiding time pressure.
Staff who don't know what is expected of them. The data for a product passport does not come into being automatically; someone has to enter it, check it and keep it current. Without clear instruction, errors arise here that later resurface during an inspection.

What you can document

A product passport does not begin with the technology, but with the administration that precedes it. Matters that a company can document now, regardless of the question of when its own product group becomes mandatory:

An overview per product of which materials, components and substances it contains, with source attribution per supplier.
A list of repair and maintenance instructions per product model, including who manages these internally.
Agreements with suppliers on periodically communicating changes in composition, so that the product passport does not become outdated.
An internal responsible person or team that takes on data entry and verification, with a clear division of tasks.
Documentation of which product variants fall under which product passport, and why.

For companies that want to know how these steps relate to each other, the step-by-step approach for the product passport a sequence that aligns with what is stated above. And because the technology behind the product passport is less disruptive than the data inventory that precedes it, it is already possible for many companies to create a test version of the product passport before there is even any question of a legal deadline. Testing this often already provides insight into what will be the most time-consuming: not the QR code, but getting the underlying data in order.

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.