How often must I update the data in the product passport?

No fixed term, but an obligation to keep information current

The ESPR itself does not set a fixed interval for updating the digital product passport — not "every year", not "within a certain number of months after a change". What is established is the principle set out in Article 9 of the ESPR (Regulation (EU) 2024/1781): the information in the digital product passport must be accurate, complete and up-to-date throughout the entire period in which the passport must remain available. This is an ongoing obligation, not a snapshot at the time of completion when placing on the market. In practice, this means that an update is necessary as soon as something changes that is relevant to the data in the passport — a repair, an adjustment to the material composition, a recall, or the end of life being reached — and not according to a fixed calendar. How this looks in detail for each product category, which party may or must carry out which update, and which part of the data is fixed when placing on the market versus is completed later, is the subject of Article 10 of the ESPR, which refers to the delegated act for each product category.

For manufacturer, importer — and the actors further down the chain

This matter concerns first and foremost the party that compiles and places the passport on the market: the manufacturer or, for imports from outside the EU, the importer. That party is subject to the obligation to keep information current under Article 9 in any case for the data that have been entered when completing the passport. This concerns not only information that the manufacturer enters itself, but possibly also data that other actors in the chain add later: a repairer who replaces a component, a recycler who dismantles the product, or a subsequent owner in resale. Article 10 of the ESPR expressly states that the delegated act for each product category must establish which market participant or actor is responsible for uploading information, including after the product is placed on the market. This means that "updating" does not automatically remain a task of the original manufacturer — for some data that responsibility may shift to another party further along in the product lifecycle. Where this does not apply: static, technical basic data that are already fixed when placed on the market, such as a unique product identification number. These do not change by themselves and therefore do not need to be reviewed periodically either.

No fixed date yet established for electronics and ICT

There is no published delegated act that establishes the precise update obligations for electronics and ICT equipment. The ESPR itself sets out the framework in Articles 9 and 10, but the detailed implementation for each product category — including any deadlines for making changes — follows from the delegated act that is yet to be published. According to the European Commission's work plan for 2025-2030, delegated acts for each sub-category are expected from 2027 onwards; no publication date is yet known for electronics and ICT. Until the moment when a delegated act for a specific product category has been published and comes into force, there is no concrete update obligation under the digital product passport for that category — the obligation to have a passport itself only arises with that act.

What this means in practice

For those already preparing now, the sequence is roughly as follows. First, map out which data will eventually be included in the passport and which of that data may change during the product's lifetime — think of repair history, software versions, or altered material composition during a model revision. Next, set up an internal process that signals such events, so that an update is not left to chance but follows from a fixed review at a recall, model change, or end of production. Designate, even though this is not yet legally required, a person responsible within the organization for maintaining passport data — that role will probably be more concretely defined with the delegated act. Finally, keep track of the publication of the delegated act for your own product category, because only then will it specify which update intervals exactly apply, which party is responsible for what, and which data are dynamic and which are fixed.

Where this is stated: Article 9 and 10 of the ESPR

Article 9 of the ESPR (Regulation (EU) 2024/1781) stipulates that the digital product passport must remain available during the expected lifetime of the product and that the information contained in it must be accurate, complete and up to date. Article 10 of the same regulation determines that the delegated act must specify per product category which market actor is responsible for entering and updating information, including after the product is placed on the market. Together, these two articles form the framework within which the actual update obligations per product category will later be worked out.

Those setting up processes now should best start with an overview of which data in their own product may change during its lifetime and with whom in the chain agreements are needed — so that a working method is in place as soon as the delegated act for their product category appears.