How long must a digital product passport remain available?
The retention period is determined per product group
How long a digital product passport must remain accessible is not specified as a single fixed number in the ESPR itself. Article 10 of the ESPR (Regulation (EU) 2024/1781) stipulates that the period during which product passport data must remain accessible is set out in the delegated act for the relevant product group, taking into account the expected lifetime of the product. There is therefore no general EU-wide period that is the same for all products: a washing machine with a long service life may have a different retention period than a smartphone or a charger. For electronics and ICT equipment, that delegated act does not yet exist, so the exact period for this category is not yet fixed.
Which part this applies to, and which does not
This concerns the accessibility of the data made available via the QR code or similar carrier of the product passport — that is, the passport as it can be consulted by the buyer, repairer or supervisory authority via the product itself. It does not concern the EU register of product passports under Article 13 of the ESPR: that register maintains its own dataset and has its own function, namely to preserve a basic set of data so that passports remain findable and verifiable, even independently of the manufacturer that originally supplied them. The retention period of the passport itself and the operation of that register are therefore two different things, both of which are in the ESPR but with a different purpose. Other retention obligations — such as files under the WEEE Directive, warranty periods, or documentation for CE marking — do not fall under this; those follow from other rules and are separate from Article 10.
The date is not yet fixed: this much is known
At present, no concrete deadline can be given for electronics and ICT equipment, simply because the delegated act for that category has not yet been published. According to the Commission's work programme for 2025-2030, delegated acts are being developed per subcategory, with the expectation that the first of these will appear from 2027 onwards. As long as such an act does not exist, there is also no legal obligation for this product group to already implement a digital product passport, and therefore no established retention period to comply with. Once the act for a specific electronics or ICT category has been published, it is expected to also contain the period for which the data must remain accessible.
What this means for your approach
For an importer or manufacturer preparing for this, the first step is to monitor the publication of the delegated act for their own product category — the actual period is only specified in that act. The second step is to take into account the principle in Article 10, namely that the period is linked to the expected lifetime of the product: for household appliances, a longer retention period is to be expected than for short-lived consumer electronics, although this is not yet an established fact as long as the act does not exist. The third step is when choosing a hosting partner to ensure flexibility: a party hosting the passport must be able to adjust the retention period as soon as the delegated act is published, rather than fixing a period in advance that turns out to be too short in retrospect. The fourth step is not to assume a specific number of years as an established fact — a stated period of, for example, ten years is currently an expectation based on comparable legislation, not a confirmed legal requirement for electronics and ICT. Anyone now collecting and structuring data for a future passport would be wise to do so in a way that can adapt to a retention period yet to be determined, rather than binding data and storage to a fixed period.
Source: Article 10 and Article 13 ESPR
The basis for this is found in Article 10 of the ESPR (Regulation (EU) 2024/1781), which sets out the requirements for the digital product passport, including the provision that the accessibility period per product group is to be determined in a delegated act with regard to the expected lifetime of the product. Article 13 of the same regulation governs the EU register of digital product passports, which has a supplementary, distinct role alongside the storage obligation for the passport itself.
Anyone preparing a passport strategy for electronics or ICT equipment now would be well advised to keep an eye on the publication of the delegated act for their own product category and to arrange their own data storage in such a way that a retention period yet to be determined can be implemented without difficulty as soon as it is known.
What this is based on
- Regulation (EU) 2024/1781 (ESPR), Article 10 (requirements for the digital product passport)
- Regulation (EU) 2024/1781 (ESPR), Article 13 (register of digital product passports)
The regulation itself is on EUR-Lex. We provide references per statement; you do not have to take our word for it.
What you must concretely do
What is expected of you
Availability throughout the product's lifetime
Article 10 of the ESPR (Regulation (EU) 2024/1781) sets out the requirements for the digital product passport, including the principle that information remains available as long as there is a reasonable need for it — think of the period during which a product is still in use, on the market, or relevant for repair and recycling. For a product category such as electronics and ICT equipment, the exact duration will only be determined in the delegated act for that product group. Until that act is published, no fixed number of years can be stated. For a company with 10 to 100 employees, this means in practice that the choice of a hosting provider or in-house system cannot be made lightly: the data must remain accessible for as long as will eventually be laid down in the applicable delegated act, and that could be a period much longer than a standard IT contract or hosting subscription.
Accessibility, not just storage
Remaining available is more than placing a file somewhere. The information must also be actually retrievable via the identification carrier on the product, usually a QR code. This relates to the question how does the QR code for the product passport get onto my electronics, because a passport that exists but can no longer be retrieved because the link with the carrier has been broken does not actually meet the purpose of Article 10. For a medium-sized company, this means that the technical chain — from QR code to server — must function as a whole, not as separate components that are each "good enough" on their own.
Registration in the European register
Article 13 of the ESPR requires the passport to be entered in a central register. That registration does not stand alone: if the passport changes location, hosting provider, or ceases to exist, the question is what happens to it in the register. More on what exactly must be included there and how it relates to the lifetime of the passport can be found on the page on what the register of digital product passports is and what must be included in it. For companies with multiple product lines, this is a recurring point of attention: any change to a passport can have implications for what is recorded in the register.
Continuance independent of the company's situation
The obligation to keep the passport available is not linked to the continued existence of the company that had the passport drawn up. This raises the practical question of what happens in the event of a merger, acquisition, bankruptcy, or simply discontinuing a particular product line. For a business that may want to sell, restructure, or wind down in the future, this is a real scenario to think through in advance — see also what happens to the product passport if a company ceases operations. The obligation does not automatically disappear with the company that once had the passport created.
Where things go wrong in practice
A hosting contract is concluded for a period that aligns with the standard IT budget cycle — for example, a couple of years — without thinking ahead to renewal. If the lifetime of the passport turns out to be longer in the delegated act than the contract, a gap emerges in which the QR code points to a dead page.
A company moves to a new ERP system and does not include the link to the product passport in the migration plan. The underlying product data change location, but the identification carrier on the product continues to point to the old address. Those who wish to prepare for this can answer the question of whether the passport can be linked to their own system sooner, see linking to your own ERP or inventory system.
A product line is phased out after a few years and the website or data server hosting the product passports is wound down because "there is no turnover on it anyway". However, the products already in use by consumers or businesses still need a working QR code, regardless of whether the product is still being sold.
When a company is taken over, the product catalogue is acquired, but no one arranges who becomes responsible for the existing passports and the associated hosting. The new owner only discovers later that there is still an obligation continuing on products that were sold years ago.
A manufacturer has the QR code printed on a sticker that is not resistant to the operating conditions of the device. Over time, the code becomes illegible, making the underlying data — no matter how long it is kept available — no longer retrievable. More information on this is available at what to do if the QR code is damaged or illegible.
What you can document
- An overview per product line of which hosting partner manages which passport data, including contract duration and renewal agreements.
- An internal document setting out who is responsible for the passport in the event of a reorganisation, sale of a product line or business transfer.
- A technical description of the link between QR code, database and any ERP system, so that this knowledge does not disappear when staff change.
- A migration protocol in case of system change, so that the identification carrier on the product always points to a working location.
- A note on each product about which unique identification code is used, relevant to keeping track of which passports belong where — see also the explanation on how each product receives a unique identification code.
- A copy of the registration data as recorded at the time of registration, so that changes can be traced later.
For most of these points, templates are available that can serve as a starting point when setting up your own file, to be adapted to your own business operations and product portfolio.
This is not legal advice. This page provides general information about the regulations that this platform covers. We are not familiar with your situation. If you are in doubt about your own case, consult a lawyer or the competent supervisory authority.
Written with AI based on the sources above, checked by a human on 2026-08-22. Is something incorrect? Let us know — corrections take priority.