What data goes into the product passport for products?
A fixed foundation, with additions per product group
Which data goes into the digital product passport depends on the product group, but the ESPR (Regulation (EU) 2024/1781) does establish a common foundation. Article 10 sets out the general requirements a digital product passport must meet: the passport must be linked to a unique product identification number, it must contain data about the manufacturer or importer, and it must be structured so that the right information is accessible to the right party — a consumer sees something different from a recycler or a supervisory authority. Which specific content data is added on top of that — on sustainability, repairability, material use, substances present, energy consumption or environmental impact — is laid down per product group via the ecodesign requirements, performance requirements and information requirements in Articles 5 to 7. In other words: the form of the passport is set out in the ESPR itself, the content is filled in product by product.
For whom this applies, and for whom it does not yet
This arrangement applies to product groups for which the European Commission has adopted an implementing measure on the basis of Articles 5 to 7. As long as that measure does not exist for a particular product group, there is no mandatory list of data for those products, and therefore no obligation to maintain a passport. This means that a manufacturer with products in multiple product groups may face different timelines and different datasets: one product group may already fall under an implementing measure, while another product group is still awaiting the fulfilment of Articles 5 to 7. The general structure from Article 10 — unique identification number, accessibility levels, link to the QR data carrier — will apply to all product groups falling under the ESPR, but the concrete content of the passport is therefore never universal for "a product", only for a specific product group.
What still needs to be established per product group
There is no fixed date on which it is clear for all product groups which data must be in the passport — that depends on the pace at which the Commission adopts implementing measures per product group on the basis of Articles 5 to 7. What is certain is the framework within which this happens: the ESPR itself sets out the general structure and the categories of information requirements (Article 10), and per product group it is then determined which of those categories apply and which data they are filled in with. Until an implementing measure for a product group is adopted, there is no concrete data list to work with for those products. Manufacturers and importers can already see how the passport will be structured, but the exact dataset per product only becomes available once the corresponding measure is in place.
How this works out in practice for you
The first step is to check whether a product category in which products are sold already falls under an implementing measure based on Articles 5 to 7, or whether it is still in preparation. If so, that measure will specify which data must be included in the passport — such as data on composition, origin, repairability, substances present and performance, supplemented with the basic data that Article 10 in any case requires, such as the unique identifier and the details of the manufacturer or importer. The second step is to collect that data from your own production and purchasing records, often spread across multiple departments or suppliers. The third step is to compile the passport itself, including the correct accessibility structure and the link to a QR data carrier on the product. At prodpas.eu, that latter part — compiling on the basis of supplied data, hosting and providing the QR code — is supported for multiple product categories at the same time, so that a manufacturer with products in different categories does not need to set up a separate solution for each category.
Where it is stated: Article 10 and Articles 5 to 7
The general requirements for the digital product passport — the structure, the unique identifier, accessibility for different users — follow from Article 10 of the ESPR (Regulation (EU) 2024/1781). The substantive data that goes into that passport per product category follows from the ecological design requirements, performance requirements and information requirements of Articles 5 to 7 of that same regulation, as these are further developed per product category.
Anyone who wants to prepare now should check per product category whether an implementing measure has already been published and what data it mentions, and draw up an overview of where that data should come from internally or from suppliers — so that the passport can be compiled quickly once the obligation for that product category comes into force.
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
The ESPR itself does not provide a ready-made list with the exact data fields that must be included in each digital product passport. Article 10 of the ESPR does describe the categories of information that a digital product passport may need to contain, and Articles 5 through 7 of the ESPR determine that the concrete content per product category is established. This means that the actual dataset for, for example, textiles, furniture or electronics varies per product category and is only finalized at the moment that a delegated act for that product category is established. What can already be said now is what kinds of obligations apply to a company with 10 to 100 employees once that delegated act is in place.
Recording and maintaining product identification
A product passport revolves around a unique link between a physical product (or a product model) and a set of data. This requires an internal process that makes clear which product code, batch or serial number corresponds to which passport data. For a company with multiple product lines and possibly multiple production batches, this means that the administration that may now be in an ERP system or Excel file must be structured well enough to be transferred automatically or semi-automatically into a passport.
Providing material and composition data
Article 7 of the ESPR mentions information requirements that may concern material composition, the presence of substances that affect recyclability, and the origin of raw materials. For a manufacturer, this means that their own procurement chain and recipe or bill of materials data must be in order: not only what is in the final product, but also where it comes from. For an importer, the task is different: that data must be requested and verified from the foreign supplier, which creates dependence on that supplier.
Including sustainability and performance data
Articles 5 and 6 of the ESPR cover ecodesign and performance requirements, such as energy consumption, lifespan, or environmental impacts. If those requirements apply to a product category, the underlying test data ends up in the passport. This is not merely a matter of retyping data: the question according to which method the values for the passport must be measured determines whether the company's own test results are suitable for use, or whether additional testing is required.
Adding repair, parts and recycling information
For some of the product categories, it is obvious that the passport also contains practical information about maintenance and end of life. Whether and how detailed that should be, and whether information about repair and parts must be included in the digital product passport and what information about recycling must be included in the digital product passport, again differs per product category. For a company that already maintains a repair manual or parts list, it is a matter of restructuring; for a company that does not yet do this, it is new work.
Making data available to the correct target audience
Not all information in a passport is intended for everyone. Some is for the consumer, some for market experts, and some only for supervisory authorities. This distinction is relevant when setting up the passport and comes up in the question who may access which data from the digital product passport. For a company that is sensitive about sharing recipe or supplier information, this is one of the first questions that must be answered before the passport is compiled.
Where things go wrong in practice
A first recurring situation is that a company wants to put the data it already has (for example for CE marking or an environmental label) one-to-one into the passport, while the delegated act for that product category requires a slightly different classification or unit. The data exists, but not in the form that is needed.
A second situation is that the material information provided by a supplier turns out to be incomplete or outdated at the moment it needs to be included in the passport. This occurs especially among importers with multiple links in the supply chain, because the request for detailed composition data is not always a standard part of the purchasing relationship.
A third situation is that a company considers information as business confidential that is actually intended for the public section of the passport, or conversely: shares information publicly that could have remained protected. This applies for example to recipes or supplier names, and is connected to the question whether business-sensitive data about products must be made public.
A fourth situation arises when a product modification — a different raw material, an adapted component — is not reflected in the already published passport. This relates to the question how often the data in the product passport must be updated, and to the question what to do in the event of a error already discovered in a published passport.
A fifth situation is that a company supplies the data only in Dutch, while the product is also sold in other Member States. This relates to the question whether the product passport must be offered in multiple languages, something that is easily overlooked when first setting up a passport.
What you can document
- An overview per product group of which delegated act applies and which data categories it prescribes.
- An internal register in which product codes, batches and serial numbers are linked to the corresponding passport data.
- Documentation of the measurement method used for performance and durability data, including the test reports on which they are based.
- A supplier overview with agreements on the provision and updating of material and composition data.
- A classification of data by target group (consumer, market expert, competent authority), so that when published it is immediately clear what becomes public and what does not.
- A procedure for correcting data after publication, including who is responsible for it.
- An overview of the languages in which the product is offered, linked to the languages in which the passport data must be available.
For companies that do not yet have these components structured, our templates offer a starting point to set up data collection per product group before the first delegated act for that group enters into force.
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.