How do I approach the product passport for electronics step by step?

The passport is created in four fixed steps

The digital product passport for a piece of electronics or ICT equipment does not come into existence all at once, but builds itself up in a fixed sequence. First, data about the product is collected: materials, origin, repair options, and any other information relevant to that product category. Next, that data is entered into a passport that can be traced via a unique identification number, with a link to the manufacturer or importer responsible for its accuracy. The passport is then linked to a physical data carrier on the product itself, usually a QR code, so that a user, trader or enforcement authority can retrieve the data. Finally, the passport must remain accessible for the prescribed period, even if the product is long gone from the shelf. This sequence — data, linking, data carrier, availability — is the core of Articles 9 and 10 of the ESPR, and applies in principle to every product for which the European Commission makes the passport mandatory.

For electronics and ICT, per product group separately

This approach applies to products that fall under the ESPR and for which a specific delegated act makes the passport mandatory. This means that the obligation does not arise all at once for 'electronics' as a whole, but is introduced separately for each subcategory — white goods for example separately from phones, and phones separately from other ICT equipment. For an importer or manufacturer, it is therefore relevant which specific product group their articles fall into, and not merely that it is 'electronics' in a general sense. This step-by-step approach does not concern other obligations sometimes mentioned in the same breath, such as ecodesign requirements on energy consumption or repairability itself — these are separate rules that may exist alongside the passport, but do not coincide with it. The passport is an information carrier, not a quality mark and not a guarantee that the product meets all requirements.

A date is not yet fixed, but the work plan is

There is not yet a fixed date on which the passport for electronics or ICT equipment becomes mandatory. The obligation arises only once the European Commission adopts and publishes a delegated act for a specific product category; that act then also determines per category from which point onwards the passport is required. The Commission's work plan for the period 2025-2030 lists electronics and ICT equipment as a category for which such delegated acts are being prepared, with an expectation that the first of these will appear no earlier than 2027. That is a planning, not a commitment on an outcome or a firm end date. Until a delegated act is in place, there is therefore no obligation for the product group concerned to maintain a digital product passport. As soon as an act is published, the associated date is fixed and will be stated here.

The practical sequence for those preparing now

Anyone who wants to think ahead about a digital product passport should do so in the order in which the obligation will actually take effect. The first step is to check which specific product category your own assortment falls under, and whether a delegated act is already in preparation for that category. The second step is to inventory the data that such a passport must contain at minimum according to Article 10 of the ESPR — these are often data that already exist somewhere within your own organisation, in procurement, quality or compliance, but have not yet been bundled together. The third step is to consider who will technically host the passport and keep it up to date, because the obligation to keep the data accessible for a longer period does not automatically shift to a third party; that choice lies with the manufacturer or importer. The fourth step is the link with the data carrier on the product, so that the QR code or similar marking at the moment the obligation takes effect actually points to a functioning passport. Anyone who works through these four steps in order will not face surprises once the delegated act for their own product category is published.

Where this is stated: Article 9 and 10 of the ESPR

This structure follows directly from the ESPR itself. Article 9 of Regulation (EU) 2024/1781 describes what a digital product passport is and how it is linked to a product via a data carrier and a unique identification number. Article 10 of the same regulation sets out the requirements that the passport must meet, including the accessibility of the data and the responsibility of the market actor who supplies the data. Both articles form the framework within which later delegated acts, per product category, fill in the details.

Anyone who wants to start right now should best begin by mapping out their own product category and the data that will be needed for it — that inventory takes no waiting time for a delegated act and is the basis for every subsequent step.