how do I arrange the product passport for all my product lines at once

One approach, completed per product line

Managing multiple product lines at the same time works best by setting up one common procedure and filling it with specific data per product line, rather than designing a separate process for each line. The digital product passport is compiled per product model, but the way you collect, verify and submit data is virtually the same for all product lines. Anyone who gets that process right once only needs to repeat it afterwards — not redesign it.

For which lines this works, and where it breaks down

This approach is intended for companies that produce multiple models or variants within the same equipment category: for example, a range of washing machines, an assortment of laptops, or different types of routers. Within such a category, the requirements and the type of data needed are very similar, which means one data collection template can be used for the entire line. That does not automatically work across categories: the delegated act of the ESPR is determined per product group, and the exact data requirements for domestic appliances may differ from those for ICT equipment. One common approach therefore means: one procedure per product category, not automatically one procedure for the entire company. It also applies that each model receives its own passport — economies of scale lie in the process and templates, not in sharing one passport between models that actually differ.

What is already fixed, and what is not

There is not yet a fixed date for when this will apply to electronics and ICT equipment. The Commission's work plan for the ESPR runs from 2025 to 2030 and addresses product groups one by one; for electronics and ICT the delegated act is not expected before 2027. As long as that act has not been published, it is not established which data is exactly mandatory and from when. What is already established is the legal framework within which this will happen: Article 9 of the ESPR (Regulation (EU) 2024/1781) provides for a digital product passport, and Article 10 of that regulation describes the requirements that the passport must meet. That foundation will not change; the implementation per product category is still to come. Anyone who does not want to stand still in the meantime can already find out what can already be done while the rules are not yet final.

How to approach this in practice

The order in which a company with multiple product lines usually tackles this starts with grouping its own models by product category — not by brand, price range or internal department, but by the category to which the future delegated act is likely to apply. Within each category, the next step is to identify which data are already available: technical specifications, material composition, repair and spare parts information, and documentation already kept for other purposes (CE marking, safety files, warranty conditions). Much of that data already exists within an organisation, only not in one place and not in the form that a passport will later require.

After that, it is practical to determine who within the company is responsible for providing and keeping that data current per product line — often a combination of product management, quality and procurement, because data on materials and origin often lie with suppliers. These steps align with the broader order described in the step-by-step approach to the product passport, and it makes sense to use that approach as a basis and repeat it per product line instead of starting from scratch each time.

For companies with many product lines, it is also practical to look early at how to plan the implementation of the product passport within the organisation, so it becomes clear which lines come first — for example, the lines for which a delegated act is expected to come earlier — and which can follow later. It is also advisable to establish who maintains the data submission per line, so that in the event of an inspection it is clear which data comes from where and who has submitted it.

The legal basis: Article 9 and 10 of the ESPR

That the passport is drawn up per model and is based on fixed substantive requirements follows from Article 9 and Article 10 of the ESPR (Regulation (EU) 2024/1781). Article 9 provides that for products that fall under a delegated act, a digital product passport becomes mandatory, and Article 10 describes what the content and technical setup of that passport must comply with. That these requirements are filled in per product group via separate delegated acts is explained in the work plan of the European Commission on the regulation on ecodesign for sustainable products. That approach — one framework regulation, with a separate elaboration per product group — is precisely the reason why a common working method works, but a common passport between categories does not.

If a company now wants to work with multiple product lines, it is best to start by organizing its own models per category and identifying the data that is already available, and then apply the fixed steps from the approach to each line once the delegated act for that category is known.

What this is based on

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

A company with multiple product lines — say an importer that markets both kitchen appliances and small ICT peripherals — does not have to manage one digital product passport, but effectively a data project per product group. Article 9 and Article 10 of the ESPR (Regulation (EU) 2024/1781) describe what a passport must contain and how it must work technically, but the delegated act per product category determines which data are mandatory for that specific group. This means that "managing the product passport" for multiple lines at the same time is primarily an organizational question: how do you set this up without each product line reinventing the wheel.

Draw up an overview of which product lines fall under which category

The first step is simply to establish which of your product lines will eventually fall under a delegated act and which will not. Not every ICT or electronics line is affected at the same time or under the same conditions; the work plan operates per sub-category. For a company with 10 to 100 employees, this is usually not a technical exercise but an administrative one: placing the product catalogue and the categories from the work plan side by side. For those who still need to start here, you will find a starting point in does the digital product passport apply to my electrical and electronic equipment.

Design one data structure that works for multiple lines

Many companies with multiple product lines share suppliers, materials or components between those lines. That is an opportunity: instead of setting up a data collection separately for each line, it is practically possible to design one basic structure — a fixed format for material data, repair information and origin — that is filled in per product line with the specific data. Article 10 of the ESPR sets requirements for how the passport is technically structured and linked to the carrier; that works the same for product A as for product B, even if the content differs.

Prioritize based on timeline per category

Because delegated acts do not appear simultaneously for all categories, a sequence emerges in practice. A company that waits until everything becomes mandatory at the same time runs the risk that multiple lines will have to be delivered simultaneously at the moment the date is actually set. A phased approach, in which preparation starts per product line when appropriate, prevents that congestion. A general approach for this is described in how do I approach the product passport for electronics step by step.

Distribute internal responsibility across product lines

With one product line, it is often sufficient for one person to collect and maintain the data. With multiple lines, this quickly becomes unmanageable, especially if lines are managed by different teams or locations. It is then helpful to document who is responsible per line for keeping the data current, and who monitors the coherence between lines so that the same supplier does not appear in five different passports with five different data.

Where things go wrong in practice

A number of patterns recur among companies that want to tackle multiple product lines simultaneously.

First: everything is treated as one large project, with the result that nothing is completed before the deadline of the first mandatory category approaches. The product lines with the most uncertainty then draw the attention away from the lines that could already have been finished.

Second: the same supplier delivers components to multiple product lines, but the data is requested and recorded separately per line. Small differences in what was provided then lead to inconsistent passports for products that actually contain the same component.

Third: a product line is phased out or replaced by a new version, but no one has documented what should happen to the existing passport — while the hosting obligation for existing passports continues, even if the product itself is no longer sold.

Fourth: responsibility for data collection lies with procurement, while responsibility for compliance with the rules lies with compliance or quality. With one product line, this can still be bridged with an email; with ten lines, a gap emerges in which no one knows whether the data has actually been entered.

Fifth: testing is delayed until all product lines are "ready", which means that errors in the basic structure only come to light late — and then have to be corrected in multiple passports at once. Testing per product line, as soon as it is ready, prevents a structural error from multiplying. See how can I test my product passport before it is published.

What you can document

For a company with multiple product lines, documentation is not only a matter of compliance, but especially of maintaining overview. It is useful to document:

An overview per product line: under which category it is expected to fall, and which delegated act will apply to it once it is published.
A shared data structure or template, so that each product line uses the same basic fields and only the content differs.
An overview of shared suppliers and components between product lines, so that data is not requested twice or inconsistently.
A distribution of responsibility: who is the point of contact per product line for the data, and who monitors the coherence across all lines.
A timeline per product line, linked to the expected publication dates of the respective delegated acts, so that preparation can proceed in phases. A tool for that planning can be found in how do I plan the implementation of the product passport in my organisation.
An overview of what each product line costs in terms of preparation and management, so that budgeting does not happen only afterwards; see also what does a digital product passport for electronics cost.
A training plan for the employees who will work with multiple passports, so that knowledge does not rest with one person; see how do I teach my employees to work with the product passport.

These documentations make tackling multiple product lines less a series of separate projects and more one coherent process — with room to switch per line once the actual obligation and date become known.

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 2026-09-05. Is something not correct? Let us know — corrections take priority.