For the digital product passport of electrical and electronic equipment, the same core set of documents typically recurs: technical documentation on the product, the declaration of conformity associated with existing CE legislation, an overview of materials and substances used, information on repair and the availability of spare parts, the instructions for use with safety information, data on recycling and treatment at end of life, and where applicable, test reports from a notified body.
The detail that stands out most with this product group is information on repair and spare parts. Where textile fibre composition is central and wood origin often features prominently in furniture, electronics places emphasis on how long a device lasts and whether it can be repaired. This makes this specific part of the document list more significant than with other product groups, and it is also the part about which manufacturers and importers receive the most questions.
The core: which documents recur
Technical documentation typically includes the structure of the equipment, the components used, and the way the product has been tested. The declaration of conformity often already exists within a company, because electrical equipment has been subject to CE legislation for some time; for the product passport, this declaration is linked to the other data rather than being drawn up anew. The materials overview describes which substances and raw materials have been incorporated in the equipment, with special attention to substances that must be reported separately. In addition, there is information on recycling and treatment at end of life, often provided by the same party that also handles existing waste management obligations for electrical equipment.
Why repair and spare parts warrant separate attention
The regulation for digital product passports is connected to a broader idea about circularity: products that last longer and are easier to repair place less burden on the environment. For electronics, this means that supervisory authorities and purchasers look at the availability of spare parts, the timeframe in which repair is possible, and whether a component can be replaced without replacing the entire device. This makes this part of the documentation substantively different from a simple materials list: it is not only about what is in the product, but about what can happen to the product after it reaches the user.
What this means in practice for your administration
For companies, this means that documentation on repair does not only need to be held by the manufacturer of the final product, but often also by component suppliers. If you assemble equipment from components from multiple suppliers, it is advisable to check for each component whether repair information is available, and whether that information aligns with what your passport requires. This is also the point where many companies realize that the existing administration does not automatically align with what the passport expects.
Where these documents come from
Part of the documentation you already have in-house as a manufacturer or importer, for example the declaration of conformity and the instructions for use. Other documents, such as detailed material information or repair data, often come from suppliers and you need to request them from them. In the knowledge base with documents per product group the specific documents for electronics are set out per situation and what the official text says about the source.
What if a document is still missing
It is not unusual for one of these documents to still be incomplete at the time a company begins with the passport. This need not be a problem as long as it is clear which document is still to follow and who it comes from. Companies that are uncertain whether their documentation is complete can see in a few questions which documents apply to their situation. For questions about how we process the supplied documents into the final passport, we explain how that data reaches us and is hosted out.
Whether a document is mandatory and in what form it must be submitted depends on the specific situation of the company and the type of device. For your own assessment of this, the official text of the regulation or the advice of a lawyer is the starting point.
Would you like to know which documents are most important in your case? Take the free quick-scan or browse the topics in the frequently asked questions about the product passport to see which document deserves attention first.