How does the QR code for the digital product passport get on my electronics?

The manufacturer or importer applies the code itself

The QR code does not appear automatically on a product: it is applied by the manufacturer or importer after the data for the digital product passport has been recorded and a unique data carrier has been created for it. The process takes place in two separate steps. First, the passport itself is compiled: the technical and product information required by the applicable delegated act for that product category is gathered and linked to a unique identification code. Only then does the physical or digital carrier — usually a QR code, but other machine-readable forms are also possible — come into being, which refers to that passport. That carrier must then actually be placed on the product, packaging or accompanying documentation, and that is an action which the manufacturer or importer carries out or has carried out themselves, not something that a platform does for them without involvement.

Who this applies to, and what it does not

This obligation depends on the product category: it only applies to a specific type of electrical or ICT equipment once a delegated act under the ESPR has been adopted for that category. Until then, there is no obligation for that product to have a QR code for a digital product passport. Moreover, it concerns new products placed on the market — not equipment already in the possession of the consumer or resold second-hand without a new market introduction. Articles 16 and 17 of the ESPR deal with labels in a broader sense, not specifically with the QR code of the passport; article 17 prohibits labels that so closely resemble an official label that they could cause confusion. That is relevant to the QR code insofar as a counterfeit or misleading data carrier could fall under that prohibition, but it is a different matter from the question of how the genuine code is placed on the product.

A date is not yet fixed

There is no fixed date yet when the QR code for electrical and ICT equipment will become mandatory. The ESPR itself is the framework, but the concrete obligation only arises per product category through a delegated act. According to the European Commission's work plan for the period 2025-2030, such acts for this sector are expected at the earliest from 2027 onwards, but this is a schedule, not a commitment to an exact date for electrical or ICT specifically. Until a delegated act for the relevant category has been published, there is no obligation under the ESPR to apply a QR code. Once the text for a category has been adopted, the date will appear here.

What this means for your approach

For those preparing for this, the sequence is obvious. First, it is important to monitor whether and when a delegated act is adopted for your own product category — only then will it become clear which data is precisely required and from which point in time. Following that is the gathering of the product data prescribed by the act, usually data that already exists in the technical documentation or in the manufacturing process. On the basis of that, the passport is compiled and assigned a unique identification code; this is the moment when a service such as this one draws up the passport and provides hosting. Subsequently, the QR code that refers to that passport is supplied, and that code must then still be physically applied to the product, packaging or associated documentation — that remains the responsibility of the manufacturer or importer themselves. Finally, it is important that the applied code cannot be confused with an existing quality mark or label, given the prohibition on counterfeit labels.

What this is based on: articles 11, 16 and 17 ESPR

The basis for the technical setup and operation of the digital product passport, including the requirements for the data carrier that refers to the passport, is set out in Article 11 of Regulation (EU) 2024/1781 (ESPR). That article governs how the carrier must function and be linked to the unique identification of the product, without itself creating an obligation for a specific product category — that obligation arises per category via a delegated act. Article 16 of the same regulation concerns labels in general within the ESPR framework, and Article 17 prohibits labels that display a misleading resemblance to official labels. Together, these articles form the framework within which the QR code must fit once the delegated act for a product category is adopted.

Anyone already engaged with this matter would be best advised to monitor the publication of the delegated act for their own product category and meanwhile put their own product data in order, so that the passport can be compiled quickly once the obligation comes into force.

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 data carrier on the product, the packaging or the documentation

Article 11 of the ESPR (Regulation (EU) 2024/1781) requires that the digital product passport be made accessible via a data carrier — in practice usually a QR code. The carrier is affixed to the product itself, or, if that is not practical given the nature or size of the product, on the packaging or in accompanying documentation. For a manufacturer of household appliances or ICT equipment, this means a choice that must be made early in the production process: does the code fit on the housing, on a nameplate, on a sticker, or does it need to go on the box or an insert? This choice affects the production facility, not only the packaging department.

The code must lead to the correct, current passport

The QR code itself is nothing more than a reference. Article 11 requires that the data carrier provides access to the product passport that belongs to that specific product. This means that the code must be linked to a unique product identification — not to a generic page reference per model. For companies that do not yet have a system for this, the basic principles can be found in how do I give each product a unique identification code?. For companies working with existing GS1 barcodes, there is often a standard that aligns well with this requirement; what this entails is described in what is GS1 Digital Link and do I need it for the product passport?.

Distinction between the product passport and other labels on the product

Article 16 of the ESPR addresses labels that may exist alongside the product passport — energy labels, for example, or other mandatory markings. For a company already working with CE marking, energy labels and nameplates, it is practically relevant that the QR code of the product passport has its own, recognizable place that is not confused with these other labels. The layout of the product — how much space there is for markings — thus becomes a point of attention in the design.

Protection against counterfeit or misleading labels

Article 17 prohibits the use of labels that in appearance or effect resemble an official label or the product passport, without an actual passport behind it. For an importer who brings together products from different suppliers, this means that it must be checked whether a QR code or other symbol on the product does not accidentally give the impression of being a product passport, when it is actually a marketing link or a warranty registration.

Where things go wrong in practice

A number of situations recur more frequently among companies introducing the QR code for the first time:

The code is affixed, but leads to an outdated version of the passport. This often happens when product changes (a different component, a different supplier) are not reflected in the linked data, while the sticker on the product remains unchanged.
One QR code is used for an entire product line, instead of a unique code per product or per batch. This typically occurs because the packaging line is not equipped to handle variable codes, and results in a passport that does not describe the specific unit.
The QR code becomes damaged or unreadable in practice due to wear, heat or cleaning, without an alternative access route being provided. What to consider in this regard is worked out in what if the QR code on my product is damaged or unreadable.
The code is placed on the packaging, which is discarded after purchase, so that access to the passport for the user is lost in the long term — while the passport itself is still online.
With a set of multiple devices in one box only one code is attached to the outer packaging, without it being clear whether it refers to one device or to the whole set. How this is solved in practice is described in how does the product passport work for a box with multiple devices in it.

What you can document

For a company that wants to systematically introduce the QR code, it is practical to document the following matters in writing — not because the regulations literally prescribe it, but because it makes the interface between production, IT and compliance manageable:

An overview of where the code is placed on each product type (housing, nameplate, packaging, leaflet), including the reason for that choice per product category.
The link between the unique product identification number and the QR code, including who within the company is responsible for generating and maintaining those identification codes — see also how do I give each product a unique identification code?.
A procedure for what happens in the event of product modifications: who ensures that the associated product passport is updated as soon as a component, supplier or specification changes.
Agreements with the packaging supplier or printer on the quality and durability of the QR code printing, given the requirement that the code must remain readable throughout the availability period of the product passport — relevant in connection with how long must a product passport remain available?.
An internal check for confusion with other labels, so that the QR code of the product passport is visually distinguishable from energy labels, warranty stickers or marketing codes on the product.
Documentation of the technology behind the link (static URL, GS1 Digital Link structure, or custom-made), especially relevant when the product passport is generated from an existing ERP or inventory system — see can I link the product passport to my ERP or inventory system?.

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.