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What changes to the product passport this year?

The digital product passport is not being introduced for all products at the same time. This article explains how the roll-out progresses per product category and why this year it matters for some businesses but not yet for others.

Whether anything changes this year for your products depends on one thing: has your product group already been designated by the European Commission, and has a separate implementing act already been published for it? The regulation itself is a framework. It does not determine all at once what must be included in a passport for all products, but gives the Commission the authority to work that out separately for each product group. This happens step by step, and so something may change this year for one product group, while another group notices nothing at all.

For you as an entrepreneur, this means the question is not "when does the digital product passport start", but "is my product group already being addressed, and what exactly has been specified". This varies by sector, and the only way to be sure is to look at the specific implementing act for your product group, not at the regulation in general.

Why not everything changes at once

The regulation gives the Commission criteria to determine which product groups come first, such as environmental impact and the size of a product group on the European market. On that basis, a separate decision is prepared for each group, with its own scope, its own requirements for the data in the passport and its own timeline. This is a deliberate choice: the requirements for a washing machine differ substantially from the requirements for textiles or for construction materials, and it would make little sense to prescribe those identically all at once.

The result is that the introduction of the digital product passport does not look like one hard date that applies to the entire European market at the same time. Instead, it looks more like a series of separate decisions that are published one after another, each with its own entry into force date. If you are looking this year for "what changes", you should actually be looking for what changes for the specific product group in which your own business operates.

What such a separate implementing act regulates

A decision per product group normally specifies which products it covers exactly, which data must be required in the passport, who in the supply chain is responsible for it, and from what point the obligation takes effect. Often there is also a transition period, so that businesses have time to prepare before enforcement actually begins.

That is precisely the reason why it is difficult to say in general terms "this year this or that will change". The details are in the text of that specific decision, not in the main regulation. If you want to know whether your product group already has such an implementing act, the official text on EUR-Lex is the source that really matters. In the knowledge base per product group we look that up for you and refer you directly to that source, so you don't have to dig through legal texts yourself.

What this concretely means for your planning

If your product group does not yet have a separate implementing act, nothing will change in practice this year with regard to your obligations, although that could change at any time once the Commission publishes a new decision. If your product group does have one, then from that point a countdown normally begins: first a period to prepare, then the moment when the passport must actually be in place.

So it is not the case that you as a company with multiple product groups can stick to one date for the entire organisation. An installation company that sells both heating boilers and electronics may face two completely different timelines. With a few questions you can immediately see an indication of where your products stand in that process, without you first having to work out which implementing act applies.

How you monitor this yourself

Because the implementation details for each product group are released one after another, this is not something where finding out once is sufficient. What is not yet confirmed today for your product group may be established in a year. Companies active in multiple product groups therefore essentially need an ongoing file rather than a one-time check.

The location of each subject on prodpas.eu is deliberately free to access, even without an account, because traceability to the official text is not something that should be behind a paywall. Anyone who wants the implementation per obligation, the deadlines and a message as soon as something changes for their own product group can have that tracked via a subscription. You can read more about how that information is compiled on the page about our working method. For your own company's situation, a legal advisor or the competent supervisory authority remains the right place to obtain certainty.

Curious whether something is already established for your product group this year? Do the free quick-scan or browse through the subjects in the knowledge base to see what is known for your situation.

This article is general information and not legal advice.