What is the difference between the digital product passport and CE marking?
CE marking is the well-known sign indicating that a product meets European requirements in the field of safety, health and the environment. That marking has existed for years and will continue to apply where it already does. The digital product passport is something different: a digital document with information about a product, such as composition, origin, repair options and recycling information, that becomes accessible via a QR code or comparable carrier.
One does not therefore replace the other. A product may both require CE marking and, in the future, fall under the obligation for a digital product passport. They regulate different things, exist alongside each other in the legislation and are also checked separately.
Two different objectives
CE marking is about the question of whether a product is safe enough to be placed on the European market. The manufacturer declares thereby, on its own responsibility, that the product complies with the relevant European directives and regulations in the field of product safety. That declaration is often brief and does not address where raw materials come from or how a product can be recycled later.
The digital product passport is about something different: transparency throughout the entire life cycle of a product. Think of information for repairers, recyclers, supervisory authorities and sometimes also consumers, about what is in a product and how it can be processed at the end of its life. That is a different objective than safety alone, and therefore also a different set of requirements.
What CE marking does and does not say
CE marking says something about conformity at the time of placing on the market. It says nothing about the composition of the product in detail, nothing about the origin of materials and nothing about what must happen to the product when it reaches the end of its life. CE marking was never intended for those questions, and that does not change because there will also be a digital product passport in the future.
Companies accustomed to the CE process do not automatically recognise what is required for the product passport. The data needed for CE are often already established in the technical documentation, but the data for the passport often have to be collected separately, sometimes from other departments or from suppliers. In the knowledge bank per topic it is set out per product group which data exactly these are.
What the passport requires
The regulation on digital product passports sets out per product group which data become mandatory, and that specification appears in stages. For one product it may be, for example, the presence of certain substances, for another repair instructions or the origin of components. That detail also determines how much work collecting the data costs, and that work is separate from what has already been established for CE marking.
Because the two processes run separately, it is prudent for a company to allocate them separately as well: someone who manages CE documentation does not automatically have to be the person who compiles the product passport. Anyone who does not yet know which data will apply to their products can have that determined in a few questions before time is spent on collection that turns out to be unnecessary.
What this means for your company in practice
For most companies, this means that two separate files will continue to exist alongside each other: the CE file as it is already known, and from now on a passport file with different data, a different carrier and a different retention period. They can use the same source, for example the same technical drawing, but the elaboration and the place where the information becomes accessible to third parties are different.
How these two files come together in practice in a production process depends on the product group and on choices a company makes itself about its organization. On the page that explains where the data comes from explains how such a passport is compiled from the data that a manufacturer or importer already has, without the CE file needing to disappear or change.
Questions that differ per product group
Whether and when the obligation for the digital product passport applies to a specific product is not set out in one general rule but is determined separately per product group. The same applies to the question of which CE directive applies: this varies per product and per market on which it is placed. For a concrete assessment of the own situation, the official text of the regulation, or a lawyer, is the appropriate point of reference. Frequently asked ambiguities about this kind of overlap are also collected on the frequently asked questions page.
Those who want to know whether and when this applies to their own products do not need to figure it out in legal language. A free quick-scan provides an initial indication in a few questions, and the knowledge bank works out per topic what is and is not established.