my product varies per batch how do I fill in the passport then

Batch differences are permitted, provided the certificate that follows

A minor difference between production batches is not in itself a problem for the digital product passport: the passport describes a product as it actually is, not a theoretical average. What matters is that the data in the passport correspond to the actual properties of the product associated with that specific QR code. If a batch has a different composition — a different component, a different supplier of a raw material, a minor adjustment in the production process — then the question is not whether that is permitted, but how that difference is reflected in the data.

For identical product groups, not for different models

This question applies specifically to products sold under a single model name or product group but whose composition varies slightly from batch to batch — think of a minor variation in a component, an alternative supplier for a component, or an adjustment that the manufacturer itself considers non-material. This does not cover situations in which a product receives a different model, a different type designation, or a fundamentally different function: that is not a batch difference but a new product, with its own passport. It also does not cover differences that change the measured or calculated performance properties of the product, such as energy consumption or repairability score — this directly affects the requirements set out in Articles 5 to 7 of the ESPR (Regulation (EU) 2024/1781), which deal with ecodesign requirements and the performance and information requirements to which a product must conform. Batch differences that affect such properties require a different approach than differences that are purely administrative or cosmetic.

No fixed date yet, but a clear roadmap

There is no fixed date yet on which the digital product passport for electronics and ICT equipment will become mandatory. The ESPR operates with a roadmap for the period 2025-2030, in which delegated acts are prepared and published per product category; for electronics and ICT this is expected from 2027 onwards. Only with the publication of that delegated act will it become clear what specific information requirements apply to this product group, and thus also how detailed batch variations must be recorded in it. Until then, there is no legal obligation to create a passport, but the general rules from the ESPR on how a passport must be structured are already in place and provide a good indication of the direction. More on how this obligation is phased in is described on the page on when the product passport becomes mandatory for electronics.

How to handle batch differences in practice

The first step is to determine whether the batch difference actually affects the data in the passport. A change in a supplier of an internal component that does not change the measured performance or composition listed in the passport may not require any adjustment. If the difference does change a value that is stated in the passport — a weight, a material composition, a repairability score — then that adjustment should be incorporated into the data for the relevant batch, so that the QR code for that batch points to the correct information. In practice, this means that product information must be maintained at batch level, or at the level of a production variant, rather than at the level of the general model name.

The second step is to determine where that batch information comes from. With many electronics and ICT equipment, components come from multiple suppliers, and not every supplier records the same level of detail about batch variations. Which data exactly are needed to record this properly is described on the page on what data you must request from your electronics supplier. For products consisting of components from different suppliers for the same component — where suppliers may thus vary per batch — it is advisable to examine how this is handled in practice on the page about multiple suppliers for the same component.

The third step is to establish a procedure: how is it determined whether a batch difference is small enough not to be reported, and who within your own organisation or at the supplier makes that decision. This is particularly relevant because the ESPR also sets requirements for preventing performance deterioration and circumvention of requirements — a batch difference that consistently remains just below a threshold value is a different scenario from genuine small production variation.

Basis in Article 10, assessed via Articles 39 and 40

The core of this question lies in Article 10 of the ESPR (Regulation (EU) 2024/1781), which describes the requirements that the digital product passport must meet — including that the data must represent the characteristics of the specific product. How those characteristics are determined follows from Article 39 of the ESPR, which concerns the test, measurement and calculation methods used to determine product data; these methods also determine whether a batch difference falls within the measured margin or not. Article 40 of the ESPR is relevant whenever a batch difference could be used to circumvent requirements or cause performance deterioration: that article focuses on preventing circumvention and performance deterioration, and thus provides the background against which a "small" batch difference is assessed.

Businesses already in discussion with suppliers about how batch data will be provided should establish this early in their purchasing agreements; how this might look is set out on the page about recording passport data in the purchasing contract. Once the delegated act for electronics and ICT is published, the exact date and precise information requirements for this product group will appear on this page.