What data goes into the product passport for electronics?

Two types of data: how the product performs and who is responsible for it

The digital product passport for electronics will soon contain two types of data: information about how the product performs, and information that substantiates and identifies it. The first type concerns matters such as lifespan, repairability, availability of spare parts, material use, recycling content and the presence of substances of concern. The second type concerns origin: who the manufacturer or importer is, what the product exactly is, which standards it complies with and where the underlying documentation can be found. Both types of data derive from the ecodesign requirements that the ESPR (Regulation (EU) 2024/1781) can establish for product groups: performance requirements on the one hand, information requirements on the other. The passport itself is the carrier in which that data come together and become digitally retrievable via a QR code or comparable data carrier.

What this covers, and what does not yet receive a passport

This structure applies to product groups for which requirements have actually been established via a delegated act under the ESPR — this happens per product subcategory, not for 'electronics' as a whole. A washing machine, a smartphone and a server each receive their own set of requirements, laid down in a separate act for that subcategory. For no electronics or ICT subcategory does that act exist at this time. Also important: the product passport is in addition to existing obligations, not in place of them. CE marking, WEEE obligations concerning waste treatment, and any energy labels remain standalone regimes with their own rules. Where overlap arises — for example because the same technical documentation is usable for multiple purposes — the delegated act determines per product group how this comes together, not the ESPR itself.

No fixed list yet: that follows per product group

Which data exactly will be mandatory is not yet determined. The ESPR is a framework regulation: it describes the types of requirements that can be imposed (articles 5 to 7) and the requirements the passport as a carrier must meet (article 10), but the concrete list of data, filled in per product group, comes only with the delegated act for that group. According to the European Commission's work plan for 2025-2030, those acts for electronics and ICT equipment are expected per product subcategory from 2027 onwards. A fixed date for a specific subcategory does not yet exist. Until a delegated act is published and enters into force, there is no obligation for that subcategory to maintain a product passport.

What to do while the list is not yet fixed

For those already engaging with this subject now, the most workable sequence is: first, inventory which technical documentation already exists — material lists, safety data sheets, repair manuals, test reports for existing legislation such as RoHS or ecolabels. That documentation will probably form the basis for part of the passport data later, even though the exact structure is not yet fixed. Next, it is worthwhile to follow which delegated act applies to your own product category, because only then will it become clear which data are mandatory and in what format. For companies that do not produce all components themselves, a third point matters: data from suppliers about materials and origin become relevant once your own subcategory receives a passport, and setting up that information flow typically takes more time than filling in a passport template itself.

Where this is stated: articles 5 to 7 and article 10 ESPR

The subdivision into performance requirements and information requirements derives from Articles 5 to 7 of the ESPR (Regulation (EU) 2024/1781), which form the basis on which ecodesign requirements are established for each product group. The requirements for the passport itself as a digital carrier — how it must be accessible, linked to identification data and carried by a data carrier such as a QR code — derive from Article 10 of that same regulation. The precise, product group-specific list of data only emerges with the delegated act established for that group; that act fills in both articles concretely.

Anyone wishing to prepare now would be well advised to put existing technical documentation in order and follow developments when the delegated act for their own product category is published — the exact dataset will only be established then, and this page will be updated as soon as that happens.

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

The digital product passport is not a loose document with free-form spaces. Article 10 of the ESPR (Regulation (EU) 2024/1781) determines that the passport contains information laid down in the delegated act for the relevant product group, linked to the performance and information requirements in Articles 5 to 7 of the ESPR (Regulation (EU) 2024/1781). For electronics and ICT equipment, this means that the precise content varies by product category: a washing machine has different fields than a laptop or a smartphone.

Product information traceable to the individual unit

The passport identifies the product: manufacturer, model number, production date and similar basic data belong in it. For a company with 10 to 100 employees, this is primarily an administrative task: these data must be linked to the unique carrier (usually a QR code) per product or per product batch, and that link must be correct at the moment the product leaves the factory.

Performance data according to the requirements in Articles 5 to 7

The core of the passport consists of the performance and information requirements that the delegated act establishes per product group, based on Articles 5 to 7 of the ESPR (Regulation (EU) 2024/1781). Think of energy consumption, durability and repair data. In practice, this means that a company must know which values are mandatory for its specific product group, and that question is answered which properties are mandatory per product group more extensively. Without that list, it is difficult to estimate which tests or calculations are still needed.

Data on repair and service life

For electronics, information about repair options is part of the core requirements: availability of spare parts, repair instructions and the like. How those repair data are concretely converted into a score is detailed on the page about how the repairability score of a device is determined. For a manufacturer or importer, this means that repair data must not only be held by their own technical service, but in a form that can be linked to the passport.

Software support for connected equipment

For ICT equipment and smart electronics, the question of how long software updates will be provided is increasingly appearing as part of information requirements. That data is not optional: it bears on the service life the product claims elsewhere in the passport. A company that has not yet established this planning can read here whether it must determine how long a device receives software updates and what principles apply for that.

Materials and raw materials used

Material composition, including critical raw materials, is among the types of data that delegated acts for electronics typically require. For companies with suppliers at multiple tiers of the supply chain, this is often the most time-consuming obligation, because own procurement administration is often not set up for this. The question which critical raw materials must be reported sets out where the line lies between "present" and "reportable".

Measurement method and measurement units

The values in the passport must have been determined according to a specific method — not merely an estimate from your own R&D department. For energy consumption and similar performance data, a harmonised measurement standard often underlies the figure that appears in the passport. What this means in practice is detailed on the page about the method by which values for the passport must be measured.

Where things go wrong in practice

A common problem is that companies collect data that are in their own quality system, but not in the format requested by the delegated act — which means that when compiling the passport, rework is still needed.

A second situation: repair data are scattered across service manuals, supplier contracts and internal wikis, without anyone having brought them together at product level.

A third pattern is that software update policy is set by the product department, without coordination with whoever compiles the passport — resulting in the update period in the passport not matching what marketing or support communicates internally.

A fourth pitfall: material data are requested from suppliers without clarity on what level of detail is needed, resulting in answers that are too rough or conversely too detailed for the passport.

A fifth situation arises when data initially entered are later found to be correct for the wrong measurement moment or against the wrong standard — with no clear indication of who may correct the error and how.

What you can document

An overview per product group of the mandatory fields, based on the applicable delegated act, so that R&D, procurement and compliance work from the same list
The measurement method and measurement standard used for each performance value, including test date and test laboratory
Repair data per product model: availability of parts, expected delivery, and instructions, linked to the model code
The internal policy for software support, with the period passed to the passport and who established that policy
Correspondence with suppliers on material composition and critical raw materials, as substantiation of what goes into the passport
An established procedure for who may correct if any of these data prove incorrect — that question comes up again at what to do if an error in the passport is discovered
An overview of which data remain internally confidential and which appear publicly in the passport, in preparation for issues arising at the disclosure of commercially sensitive data

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.