how does the product passport work for a box with multiple devices in it

Each device in the box receives its own passport

A box containing multiple devices — think of a set of earbuds with charging case, or a router sold together with an adapter — does not change the basic principle: each product with its own identification code receives its own digital product passport. The packaging itself is not a "product" within the meaning of the ESVR and therefore normally does not receive a separate passport. What matters is whether the individual devices in that box are regarded as independent products and fall under a regulated product category. If that is the case, each device must be accompanied by its own unique identification code and its own passport, even if they are physically sold as a single unit.

Loose accessories are treated differently than the main device

The distinction made here turns on the question of whether a component in the box independently falls within a product category that has been brought under ESVR regulation. A main device — the laptop, the washing machine, the telephone — will usually fall under it once the relevant delegated act comes into force. A loosely supplied component, such as a power cable, a replacement brush, or a simple cleaning cloth, is usually not an independent product subject to its own passport requirement. This does not apply to situations in which the supplied component is itself a regulated product — a charger, for example, may fall under its own category, separately from the device with which it is supplied. It also does not apply to products that consist of multiple components that are all subject to one and the same regulation; in that case there may be a situation in which multiple passports together belong to one sold unit, which is a different question from that of the packaging in itself. Anyone wondering whether a specific device falls under the regulation at all will find the basis for this on the page on whether the digital product passport applies to your electronics.

The date is not yet fixed, per product category

There is not yet a fixed date on which this obligation applies to electronics and ICT equipment. The ESVR works with an action plan in which a delegated act is drawn up and published per product category; for electronics and ICT, this is expected, on the basis of the action plan 2025-2030, from 2027 onwards at some point, but the exact date is only fixed once that act has been published. Until then, there is no change to existing obligations regarding packaging, labelling or product information. As soon as the act for a sub-category is published, that will be tracked here.

What this means for anyone assembling or importing a set of devices

Anyone assembling a package with multiple devices in it is well advised to first establish individually for each device whether it falls under a regulated product category. This is done independently of the question of how it is sold — as a loose unit, as a bundle, or as a set in one box. Next comes the question of whether each of those devices needs its own unique identification code; the way this is set up is described on the page on how you assign each product a unique identification code. This is followed by the question of how the QR code ends up on each device — this can differ per device, especially if the components in the box are of different sizes or materials; this is covered on the page on how the QR code is affixed to the product. Anyone bundling multiple devices together is also well advised to consider how those passports will subsequently be delivered and hosted — in practice this can be handled in a combined manner, even if legally it is a matter of separate passports. If in doubt about the precise delimitation of what counts as a "product" within a set, the official text of the applicable delegated act is the place to confirm this, once it has been published.

Where this is stated: Article 12 and Article 11 of the ESVR

Article 12 of the ESPR (Regulation (EU) 2024/1781) regulates the unique identification code and links it to the product, not to the packaging in which the product is sold. Article 11 of the ESPR describes the technical design and functioning of the digital product passport, and is based on one passport per product identification. Both articles show that the passport is linked to the product itself and to the code associated with it, and not to the physical packaging unit in which that product reaches the customer. The precise definition of what qualifies as an independent product within a bundled package will be further specified per product category in the corresponding delegated act — that text is also the place to refer to once it is available.

For those now assembling an assortment with bundled devices, it is best to start by drawing up an overview of which devices in those boxes will independently fall under a regulated category, and from there determine which identification codes and passports will be needed per unit once the relevant act is published.

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

A box containing multiple devices is common in practice: a set of earbuds with charging station, a bundle package of a router and an amplifier, or a collection box with several small ICT accessories sold as a single sales unit. The question that arises is simple: does that box get one passport, or does each device within it need its own passport? At this moment, the ESPR does not yet provide a ready-made answer for every conceivable configuration, but the text of the regulation does provide a number of starting points with which to approach that question.

What is expected of you

Each product receives its own unique identification code

Article 12 of the ESPR (Regulation (EU) 2024/1781) regulates the unique identification code assigned to a product. The regulation is based on the principle that a product passport belongs to a product, not to a package. When a box contains two devices that are each considered independently as a product — for example, a headphone and a separate charging station that could also be sold separately — it is logical that each of those devices receives its own identification code and thus its own passport. For a company with 10 to 100 employees, this means in practice that the administration is set up per article number, not per sales unit. For those who have not yet set this up that way, background information on the structure of that code can be found on the page about how each product receives a unique identification code.

The passport must identify the correct product, even if it is in a set

Article 11 of the ESPR (Regulation (EU) 2024/1781) describes the technical functioning of the passport: it must provide reliable access to the data belonging to that specific product. In a package with multiple devices, this means there is no room for a passport that "covers a bit of everything" — the passport of the charging station must show the data of the charging station, and not a mixed set of data about the entire box. In practice, this translates into the question of which device carries which QR code, and where exactly that code is attached: to the device itself, to a sticker inside the package, or to the box. That choice is described on the page about how the QR code ends up on electronics.

Components that are not an independent product follow the main product

Not everything in a box is by definition a separate product with its own passport. A loose supplied cable or a power adapter that is not placed on the market as an independent product typically belongs to the main product and does not receive its own passport. The distinction between "loose component of a product" and "a second product in the same box" is therefore the core of this question, and this distinction is not equally clear in every set. Companies that are uncertain whether their composition requires multiple passports will find a more detailed explanation on the page about what happens if a product requires multiple passports.

The data must remain linked to the correct device even after sale

A passport is not only consulted at the time of purchase, but also later — during repair, recycling or resale. With a set package, it is conceivable that the two devices are no longer together at some point: the charging station breaks down, the headphones remain in use. The passport must still belong to the correct, individual device. This requires a link that is not dependent on the packaging in which the product was once sold, but on the device itself. Companies that want their passport data to be derived from an existing system will read on the page about linking the passport to an ERP or inventory system how that link is set up at article level rather than packaging level.

Where things go wrong in practice

A number of situations come up regularly with companies dealing with set packages for the first time:

One QR code on the box, for two devices. One code is placed on the outside of the packaging, while there are two independent products inside, each requiring its own passport. The buyer who, after a year, only has the charging station left, can no longer access the correct information.
Unclear about what a "standalone product" is. A loose battery pack is sometimes seen as an accessory and sometimes as a separate product, depending on how it is sold. This assessment is not always made consistently within one product line.
The packaging disappears, the code disappears with it. When the identification code is only on the box and not on the device itself, that code can no longer be consulted after the packaging is thrown away. This relates to the question of what happens if the carrier on the product itself becomes damaged, as described on the page about a damaged or illegible QR code.
Set compositions change without the passports being updated. A manufacturer changes the contents of a bundle — a different charger model, a new colour — without updating the identification codes and passport data of the individual devices.
Confusion between passport and registry entry. It is assumed that it is sufficient to register the set package as a whole in the overview of registered passports, while registration per product is expected. How that registration works is described on the page about the European register of digital product passports.

What you can document

For companies that assemble set packages, it is useful to document a number of decisions before the first QR codes are printed:

An overview per sales unit: which individual devices are in the box, and which of these are considered as standalone products.
The justification for this classification — why a component is or is not treated as a separate product with its own identification code.
A documented link between the article number in your own system and the identification code that is assigned to the passport.
Agreements with the packaging supplier or printer about where which QR code is placed: on the device, on a loose sticker, or on the box.
A procedure for what happens when the composition of a bundle changes, so that identification codes do not continue to refer to an old configuration.

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.