A regulation applies directly in every Member State without a country having to first convert the text into its own legislation. This means that the rules for the digital product passport in Germany, France or Poland are substantively the same as in the Netherlands. What does differ per country is who checks whether a company complies with them: the designated supervisory authority, the method of checking and the practical handling of notifications are a national matter.
For a company selling products in multiple EU countries, this means there is no single central European authority that checks everything. Each Member State appoints its own market surveillance authority, and that authority supervises products placed on or made available on the market of that country. This is not a new principle — it is the same arrangement that has long existed for product safety in general — but it is something to take into account once a product is marketed in multiple countries.
One regulation, different supervisory authorities
The underlying idea is that market surveillance in the EU is organized per Member State, with cooperation and information exchange between the supervisory authorities themselves. The Netherlands has its own designated authorities for this; other countries have their own equivalent, often with a different name and a different way of working. The powers that flow from the regulation apply the same everywhere, but the way a supervisory authority acts on them — which products receive priority, how an inspection proceeds, which language is used — is organized at national level.
For a manufacturer or importer, this means above all that the question 'which supervisory authority do I need to think about' has no fixed answer. It depends on which country the product is sold in and, in case of doubt, who in that country is designated as the competent authority for the product group in question. For questions about their own situation, the competent supervisory authority in the country in question is the appropriate address, not a general explanation on the internet.
What remains the same, regardless of country
What does not differ per country is the content of the passport itself and the data it must contain. The regulation describes what information a digital product passport must minimally contain, and these requirements apply in the same way throughout the EU. A digital product passport that complies with European requirements therefore does not need to be reorganized with different content per country. What can differ is the language in which certain consumer information must be made available, and sometimes additional national requirements that exist separately from the regulation for specific product groups.
Those wishing to verify this for their own products will find in the overview by topic in the knowledge base per product group what the official text states, with a reference to the source itself.
Cross-border sales and enforcement
Supervisory authorities in different Member States work together and exchange information, precisely because products move freely across the internal market. A signal that arises in one country can therefore also be relevant for another country where the same product is sold. This is not a reason for concern, but it is a good reason to keep the data in the passport consistent and up to date in all countries where you are active. An outdated or incomplete passport is more likely to be noticed, regardless of which country this happens in.
For companies selling through multiple distribution channels or platforms in different countries, it is also important to know that the role of "producer" — the party responsible for making the product passport available — is not reassigned per country. That role derives from the regulation itself and does not change depending on the country where the product ends up.
Practical: what does this mean for your administration
In practice, this means that one well-set-up product passport, with the correct data and a working QR data carrier, is in principle usable for sales in multiple EU countries. It is mainly the surrounding environment — language, additional national requirements, and the supervisory authority you may be dealing with — that can differ per country. Companies that manage their passports via one platform have the advantage that changes are made in one place rather than repeated per country.
If you would like to know what this process looks like in practice, please read how we collect the data for the product passport how data is recorded and hosted, regardless of which countries the product is eventually sold in.
Stick with the source, even across borders
Because this topic can differ per product group and per country, it is advisable not to rely on general assumptions in case of doubt. The official text of the regulation is binding for everyone, and the competent supervisory authority in the country in question is the right address for questions about enforcement there. A lawyer with experience in international legislation can help if the situation is specific enough to seek advice.
Would you like to get a picture yourself of what applies to your products and your sales countries? Then you can get a first indication in a few questions, or contact answers to frequently asked questions. The free quick-scan gives you an initial overview of where you stand without any obligations.