how do I teach my employees to work with the product passport

Employees mainly need knowledge of their own process

Preparing employees for the digital product passport mainly means helping people understand what changes in their own part of the process, not that everyone reads the entire ESPR (Regulation (EU) 2024/1781). Those who collect procurement data need to know which information will be required and where it should come from. Those who have customer contact need to know what a product passport is and what the QR code on the product refers to. Those responsible for the assortment need to know which product groups are on the agenda and when. That is three different trainings for three different roles, and that works better than one general explanation about the regulation for the whole organisation.

This is about roles within the company, not about legal training

This preparation is intended for the people who will work with the passport: procurement, product management, quality, customer service and possibly IT. It is about what they must do in practice — providing data, placing a QR code, answering questions from customers or supervisors — and not about explaining the regulation article by article. The latter is the responsibility of whoever carries the compliance responsibility, and that person needs different background information than colleagues who use the passport daily.

This is also not about whether the passport is already mandatory for a specific product. That varies by product category and by delegated act, and the training content for employees does depend on that — but you answer that question separately. More on this can be found at whether the digital product passport applies to your electronics.

There is no fixed date, but there is an order that is already known

A firm entry date for most electronics and ICT categories is not yet fixed. The delegated acts that regulate this per product group are expected according to the Commission's work plan from 2027 onwards; as soon as such an act is published, the date for that category is fixed and not before. What is already established is the way in which the Commission selects and prioritises product groups: Article 18 of the ESPR (Regulation (EU) 2024/1781) describes the criteria on which this is based, such as environmental impact and sales volume. This means that the order in which categories come up for consideration is already somewhat predictable, even though the calendar date is not yet there.

For staff preparation, that is a reason to start now with the basics — what is a passport, who does what — and add category-specific details later once they are known. Waiting until everything is fixed means waiting until there is no time left to train.

This is how you approach staff preparation

The first step is to determine which roles in the organisation will actually deal with the passport. This is usually a smaller group than expected: not everyone in the company needs to know equally much, and too much general explanation in advance often means that no one remembers what is relevant for their own task.

After that, it is useful to determine per role what specifically changes. For procurement and quality, this involves collecting and providing product data — materials, origin, repair data — for which Article 9 and Article 10 of the ESPR (Regulation (EU) 2024/1781) describe the substantive and technical requirements for the passport. For those in the supply chain, Article 38 is important: that article describes what is expected of actors in that chain when providing and passing on passport information, and that therefore also affects employees who manage suppliers or are themselves part of a chain. For customer service and sales, it is especially relevant how the passport is shown to the customer and what questions might arise about it.

A third step is to display the passport once before it is actually published, so that employees do not encounter its operation for the first time when a customer looks at it themselves. How testing works in practice is described at how you can test the passport before going live.

A fourth step, which is often skipped, is to check whether the preparation is independent of one product line or whether multiple lines are being addressed at the same time. For companies with a broad assortment, it is more efficient to set up the training around the process rather than around one product group, especially if multiple product lines at the same time fall under the new rules. This prevents the same explanation from having to be given three times separately.

Finally, it is advisable not to view staff preparation in isolation from the company's broader planning. If someone already has a timeline for implementing the passport, the training can be aligned with it instead of making it a separate project.

The basis in Articles 9, 10, 18 and 38 of the ESPR

What employees need to know follows directly from what the regulation requires of companies. Article 9 of the ESPR (Regulation (EU) 2024/1781) describes what a digital product passport is and what function it has; Article 10 describes the technical and substantive requirements that the passport must meet. Article 18 describes how and on the basis of which criteria product groups are prioritised, which forms the basis for planning per category. Article 38 describes the requirements for actors in the supply chain, which directly affects the role of procurement and supplier management within an organisation. Together, these articles form the substantive basis from which a training programme per role can be built.

Where to start

A practical first step is to map your own roles and processes using the general approach described at implementing the product passport step by step, and from there determine which employees need which information and at what time.