What does a product passport for electronics cost?
A fixed amount does not yet exist
What a digital product passport for electronics will cost cannot be answered with a figure right now — and not because that answer is hidden somewhere, but because it does not yet exist. Article 9 of the ESPR (Regulation (EU) 2024/1781) stipulates that a digital product passport will come and which building blocks such a passport must have at minimum, but the regulation itself names no price, no tariff and no cost estimate. What the passport must contain precisely per product group — and therefore how much work and which data are required — is laid down in delegated acts that the European Commission draws up per product category. As long as that act for electronics and ICT does not exist, any price quotation is an estimate, not a fact.
For electronics and ICT, not for all products at once
This ambiguity applies specifically to electronics and ICT equipment, and even within that not for everything at once: the ESPR works with a work plan in which the Commission determines per product group which requirements apply and when. A manufacturer of large household appliances and an importer of small household appliances can thus face different requirements at different times, even though they both fall under the same regulation. What also does not fall under this: existing obligations such as CE marking, the RoHS Directive or the WEEE Directive for electronic waste. Those costs are already fixed in existing regulations and are separate from the digital product passport — the passport will be added on top in the future, not in place of.
From when onwards, and what applies until then
There is no fixed date for electronics yet. The European Commission indicates in its work plan for the ESPR (2025-2030) that delegated acts are expected per product group from 2027 onwards, but that is a plan for the whole of product groups, not a commitment for electronics specifically and not a hard deadline. Until the delegated act for a product group has been published, no obligations from Article 9 of the ESPR apply to that group. That does not mean there is nothing to do: existing obligations (CE, RoHS, WEEE, technical documentation) remain in full force, regardless of the pace at which the digital passport is rolled out.
What this means for preparation
Anyone already dealing with this subject is well advised to follow the order that the legislation itself also follows. First: check whether and when the own product category appears in the ESPR work plan — that determines whether a delegated act for that group is to be expected at all this decade. Then: get the own product data in order, regardless of the end date. Material composition, repair data, origin of components and warranty information are the kind of data that appears in virtually every implementation of Article 9, and collecting that takes time, regardless of when the obligation takes effect. Only when the delegated act for the own product group has been published does it become clear which fields are mandatory and how extensive the passport must be — and only then can a realistic cost estimate be made, because the scope of work is directly linked to the scope of the requirements. A platform that compiles the passport, hosts it for ten years and supplies the QR data carrier can make that estimate once the requirements are known; anticipating a figure without those requirements is guesswork.
Where this follows from: Article 9 ESPR and the Commission's work plan
Article 9 of the ESPR (Regulation (EU) 2024/1781) establishes the obligation for a digital product passport and describes the elements it must comprise, but leaves the detailed requirements for each product group to delegated acts. The European Commission describes on its page on the ecodesign regulation for sustainable products that these acts are drawn up product group by product group according to a work plan running from 2025 to 2030, with delegated acts expected from 2027 onwards. Neither source contains a cost indication, rate or fee — that information is simply absent because the underlying requirements do not yet exist.
What to do now
Anyone wanting to know what a passport for a specific product will cost is best advised to first check whether and when that product group is included in the Commission's ESPR work plan, and in the meantime to put their own product data (materials, origin, repair and warranty information) in order. Once the delegated act for the relevant category has been published, the associated information on the requirements and approach will appear here.
What this is based on
- Regulation (EU) 2024/1781 (ESPR), article 9 (digital product passport)
- European Commission — regulation on ecodesign for sustainable products
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
The ESPR (Regulation (EU) 2024/1781) requires in Article 9 that products falling under a delegated act be provided with a digital product passport. The regulation itself does not specify an amount for what compiling, hosting or disclosing that passport may or must cost. What costs actually fall on a company therefore depends on choices still to be made: by the European Commission in the delegated act per product category, and by the company itself in how it organises the obligation.
Yet it is already possible to say something about what those costs are likely to consist of, because the obligation in Article 9 mentions a number of building blocks, each of which represents a cost item.
Collecting and structuring data
A product passport consists of data: on materials, origin, repair options, and other characteristics that are determined per product category. For a company of 10 to 100 employees, this above all represents an organisational cost item: someone must find out which data already exist (for example from suppliers), which data are missing, and how that data are kept up to date. That is work, even if the platform that compiles and hosts the passport then takes some of the technology off your hands.
Having the passport compiled and made accessible
Article 9 requires that the passport is accessible via a data carrier (in practice often a QR code) and remains available for a certain period. This requires hosting and a technical link between product and passport. This is one of the few parts where a company can already take exploratory steps before the final date of the delegated act, for example by determining which product lines are first in line. See for this what can I do now while the rules are not yet final.
Keeping the passport up to date
A passport is not a one-time exercise. Changes in composition, repair data or other characteristics must be implemented as long as the passport must remain available. For companies with multiple product lines, this maintenance quickly mounts up, especially when different lines fall under a delegated act at different times. Anyone wishing to keep track of this would do well to determine in advance how the digital product passport for all my product lines at the same time is tackled, instead of starting over for each line.
Where things go wrong in practice
A number of situations recur more frequently in practice than others.
Costs are estimated based on other sectors. Because the delegated act for electronics has not yet been published, there is no firm basis for a cost calculation. Companies that still want to quote a figure sometimes base themselves on reports about other product categories within the ESPR, while the requirements may differ per category.
IT cost is included, data cost is not. There is often a focus on what a supplier of digital passports charges for hosting and QR codes, while the internal work of collecting, verifying and keeping data up to date costs at least as much time and money.
We wait until the date is set, and then there is no time left. Once the delegated act is published, there will probably be a period between publication and the date the obligation comes into force. Companies that do no preparation must use that period to do everything at once: collect data, set up systems, train staff. Planning that starts earlier spreads those costs. See how do I plan the implementation of the product passport in my organisation.
Staff is not included in the cost estimate. The technology of compiling a passport is one thing; employees who know how to work with it in sales, service or inspection is another. This requires training, and training costs time that is often not included in an initial cost estimate. See how do I teach my employees to work with the product passport.
There is no prior testing, so errors only come to light when going live. A passport that displays incorrect or incomplete data after it has already been published costs more to correct than if that is noticed beforehand. See how can I test my product passport before it is published.
What you can document
Even without a fixed cost estimate, there is already quite a bit to document now, so that the eventual costs can be better understood when the delegated act is in place:
- An overview of which product lines are expected to fall under the ESPR, and whether that timing differs per category. This relates to the question does the digital product passport apply to my electrical and electronic equipment.
- An inventory of which data per product line are already available (from own production or from suppliers) and which are still missing.
- An overview of current suppliers of hosting, QR codes or comparable services, including what they already offer and under what conditions.
- A plan that indicates when which step will be taken, so that costs are spread over time rather than occurring all at once. See how do I approach the product passport for electronics step by step.
- A basic document about what a digital product passport for electronics precisely entails, in order to have a shared understanding internally (in procurement, IT and management) of where the money will eventually go. See what is a digital product passport for electronics.
Once the European Commission publishes the delegated act for electronics, more concrete requirements will follow from it — and with that a better substantiated picture of the costs. Until that time, a cost estimate for a product passport necessarily remains an estimate based on the building blocks that Article 9 of the ESPR (Regulation (EU) 2024/1781) already mentions, not based on amounts that are already available.
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.