What does the product passport mean if I import electronics from outside the EU?

What you must concretely do

What is expected of you

A company importing electronics from outside the EU is usually the "manufacturer" under the ESPR — the party that first places the product on the EU market. This entails its own set of obligations, separate from what the manufacturer in China, Taiwan or the US has or has not already done.

Check whether the passport exists and is correct

Article 29 of the ESPR (Regulation (EU) 2024/1781) requires the manufacturer to verify that the product is accompanied by a digital product passport and that this passport is accessible via the data carrier (usually a QR code). For a company with 10 to 100 employees, this means in practice that the purchasing department or quality officer checks with every shipment whether the QR code works and whether the data behind it matches the delivered product. This is different from simply assuming that the manufacturer "will have sorted it out". What this check should look like in detail is described at how do I check whether my supplier's data is correct.

Verify whether the manufacturer has fulfilled its obligations

In addition to the passport itself, Article 29 requires the manufacturer to verify whether the manufacturer has fulfilled its other obligations — such as the required conformity documentation and marking. For a manufacturer doing business with a factory outside the EU, this is often the point where confusion arises: the factory supplies a product, but does not automatically supply the paperwork with it. Which data are needed for this and how to request them is set out at which data must I request from my electronics supplier.

Include own name and contact details

The manufacturer includes his name, registered trade name or brand and contact address on the product, the packaging or accompanying documentation, so that it is traceable. This is an administrative step that for companies that have been sourcing outside the EU for some time usually already happens for other regulations (CE marking, general product safety), but which can now also be checked in connection with the product passport.

Take customs controls into account

Article 15 of the ESPR provides that customs can check at the entry of goods into the EU border whether the digital product passport is present and accessible, through risk analysis and data exchange with economic operators. For a manufacturer, this means that the passport is not something that must be in order only after the border — the information must already be in place when the shipment is declared. Practically speaking, this requires coordination between the department handling the customs declaration and the department managing the passport data, so that a shipment is not delayed because the QR code is not yet active or refers to an empty file.

Where things go wrong in practice

A number of situations recur more frequently in practice than others.

The factory delivers a product sheet, not passport data. Overseas manufacturers are often used to sending a datasheet, test report or declaration of conformity, but these documents are not automatically suitable for processing in a digital passport. Structured data on, for example, repair options or material composition are then missing.

The QR code refers to a page that no longer exists. When importing through multiple intermediaries, the data carrier on the product often refers to a system of an earlier link in the chain that has since been closed or modified. The manufacturer usually only discovers this during a spot check or inspection, not when the goods arrive.

One product number, different factories. Companies that work with multiple factories for the same product for cost reasons or supply security face the question of whether one passport is sufficient or whether each factory should supply its own version. This relates to the question addressed at multiple suppliers for a product, how does the passport work.

Subcontractors out of sight. A manufacturer outside the EU often outsources components to its own subcontractors, whose existence the importer is not always aware of. If material data from that subcontractor are needed for the passport, this creates a gap in the information chain that the importer cannot fill on their own without escalating the request. must my subcontractor also provide product passport data.

Composition varies per shipment. For electronics that contain slightly different components per production batch — a different battery supplier, a different circuit board — it is not self-evident that one fixed passport will remain accurate. This bottleneck is elaborated on my product varies per batch, how do I fill in the passport then.

What you can document

For an importer who wants to maintain control over these obligations, it is practical to put a number of things in writing and make them traceable:

• Contractual agreement with the factory regarding delivery of passport data, including the moment at which these must be available (before shipment, upon arrival, or earlier). An example of what such an agreement might look like is available on how do I record the delivery of passport data in my purchasing contract.
• A fixed procedure for checking the QR code and the underlying data upon receipt of each shipment, with a documented check moment and responsible employee.
• An overview of which factory, subcontractor or supplier provides which data, especially for products with multiple suppliers or varying composition.
• A file with evidence of the importer designation on product, packaging or documentation, so that traceability is demonstrable.
• An escalation agreement for the case in which a supplier does not deliver the data, delivers them late or incompletely, including who within the company takes action on this. What to do if this situation occurs is described on my supplier is not delivering the data, what can I do.

These documentations make the passport not a one-off action upon import, but a recurring part of the purchasing process — precisely where most risks lie when importing from outside the EU, because the importer does not always have visibility into what is happening upstream in the chain.