how can I test my product passport before it is published

Testing before publication is not a separate legal procedure, but it is practically necessary

Testing a product passport before it goes live is not a step that the ESPR prescribes by name and article number — the regulation describes what the passport must be able to do and contain, not how a company verifies this before publication. Nevertheless, testing is indispensable in practice, because Article 10 and Article 11 of the ESPR (Regulation (EU) 2024/1781) set requirements for the functioning of the passport — such as linking to the correct QR data carrier, accessibility of data and the manner in which the passport functions technically — which cannot be assessed without actually opening, scanning and going through the passport as a supervisory authority or end user would do later.

For whom this is relevant, and what it is not about

This question applies to every party responsible for compiling and publishing a passport — manufacturer, importer or a party doing so on their behalf — who wants to know whether the passport is correct before it is linked to a product and the QR data carrier goes out into the world. This is explicitly not about a mandatory, formal test procedure imposed by the legislator, nor about conformity assessment or market surveillance in the sense of inspection by a third party. Nor is it about whether the content of the passport has been legally correctly compiled — that is a question about the data itself, not about the technology of testing. Anyone who wants to know which data must be included and whether the passport is even applicable to a particular product will find the answer more readily in the question does the digital product passport apply to my electrical and electronic equipment.

No fixed date yet, but a clear direction

There is no established date for the obligation to have a digital product passport for electronics and ICT equipment; this follows by product category from delegated acts expected from 2027 onwards within the ESPR work plan 2025-2030. What is established is the framework within which such a passport must function: Article 9 of the ESPR describes what a digital product passport is and what role it plays, Article 10 describes the requirements that content and accessibility must meet, and Article 11 describes the technical design and operation, including the data carrier. Until the precise date per sub-category is published, there is therefore no legal test obligation — but the requirements to which testing would have to be carried out are already largely established.

How this is tackled in practice

Anyone who starts working with a passport now would be well advised to build the test in a few steps, in the order in which a check would later also take place. First, it is checked whether the QR data carrier works technically: does it scan smoothly and does it lead to the correct, up-to-date passport page — this directly concerns what Article 11 of the ESPR describes about the technical design of the data carrier. This is followed by a check of the content against what Article 10 requires: are the correct data included, are they up-to-date, and are they actually accessible to the intended target groups (consumer, market participant, supervisory authority) without unnecessary barriers. The passport is then tested to see whether it also holds up under repeated use: does the link remain accessible for ten years, what is the intention for hosting, and does nothing unintentionally change in data that has already been published. Testing in a production environment before the actual launch — with a test product or a non-publicly visible passport page — prevents errors from being noticed only after the passport is already shown to customers or a supervisory authority. This aligns with what a supervisory authority typically wants to see in an inspection; anyone wishing to prepare for this will find more information in what does a regulator ask for when inspecting electronics. For companies with multiple models or brands, it is also practical to standardize the test process itself, so that each passport is not manually checked again — something that aligns well with the approach described in how do I arrange the product passport for all my product lines at once.

What this means and where it is based

That a passport is tested before publication does not follow from an explicit testing obligation in the ESPR, but from the combination of Article 9, 10 and 11 of Regulation (EU) 2024/1781: together they describe what a digital product passport is, what data and accessibility are required, and how it must function technically via the data carrier. A passport that meets those requirements as soon as it goes live can in practice only be guaranteed by checking it in advance against precisely those points. As long as the delegated act for the relevant sub-category has not yet been published, the exact content of the test preferably remains flexible, but the core — functioning data carrier, correct and accessible data, stable hosting — will presumably not change substantially.

Anyone wishing to start testing now should first set up a test environment separate from the final publication, then run through their own data against the requirements of Article 10, and subsequently check the technical side of the QR data carrier according to Article 11 — an approach that aligns well with the broader steps described in how do I approach the product passport for electronics step by step.