Two questions determine the answer
The regulation on digital product passports does not impose an obligation on all companies at once. It applies at the moment your product falls within a product category for which it has been separately established that a passport is mandatory, and you act as a supplier of that product on the EU market — usually the manufacturer, the importer, or someone explicitly authorised to do so.
For most SMEs, this therefore comes down to two questions. First: does your product category already fall under the regulation, or is it on the schedule? Second: is your role in the supply chain one that the regulation designates as a supplier, or are you, for example, only a distributor or seller without your own obligation? Both questions can be answered separately for each product category once the official text provides clarification.
Not one regulation for all products at once
A common assumption is that the regulation will apply to all products at once from a certain date. That is not how the system is structured. The regulation itself forms the framework; which product categories actually need a passport and from when is worked out separately for each product category. For one category this may already be concretely established, for another category not yet. What is not yet established cannot be said with certainty at this time, and you should not read it anywhere as an established fact.
In practice, this means you do not look for one entry date for 'the regulation', but for the status of your own product category. Some sectors will get clarity sooner than others, simply because the elaboration for each category proceeds at its own pace. In the knowledge bank by subject this is broken down by product category, so you do not have to search through the full text of the regulation.
Your role in the supply chain matters
The second question concerns your position. The regulation distinguishes roles: who designs and places the product on the market, who imports it from outside the EU, and who is authorised on behalf of one of the two to meet the obligations. A company that only resells products without being a manufacturer or importer itself may be in a different position than a company that places the product on the market under its own name. For an installation company that imports equipment itself, that is different than for a shop that only resells the same equipment.
These two questions — product category and role — are connected. A company can act as an importer in one product category and only as a customer in another. This makes it difficult to say in one sentence 'this applies or does not apply to my company': the answer differs depending on which product you supply.
What you can check now
Without drawing conclusions in advance about your own situation, there are things you can map out yourself. An overview of the product categories you supply, and the role you play in them (manufacturer, importer, authorised representative or only seller), gives a first picture of where the regulation may come into play. It is also useful to know which data about your products are already fixed, and which systems manage that data — that is also the conversation you will have with your software supplier at some point.
As a first step, without this saying anything about your eventual obligations, you can see where you presumably stand with a few questions. The scan provides an indication based on the product categories and roles that the regulation distinguishes, not a legal assessment of your company.
When it (not yet) applies to you
It may also be the case that your company is not affected at this moment: the product category has not yet been developed, or the role your company plays falls outside what the regulation designates as a supply chain actor. This is not a definitive outcome — as more product categories are developed, the situation may change. It is therefore advisable not to treat this as a one-time check, but as something you revisit whenever new product categories are designated.
For a precise explanation of concepts such as supply chain actor, manufacturer and authorised representative, and for answers to frequently asked questions, the collection of frequently asked questions is a logical next step. You will also find there how prodpas.eu links the source in the official text to each answer, so you can verify yourself where a statement is based.
This explanation is descriptive and does not address your specific business situation. For a judgment on your own position, the competent supervisory authority or a legal professional is the appropriate party; prodpas.eu will help you sharpen the right questions before you have that conversation.
Would you like to get an initial impression without any obligations? Take the free quick-scan or browse through the topics in the knowledge base to see which product categories and roles may be relevant for your company.