The digital product passport applies in essence to manufacturers and importers who place electronics or ICT equipment on the European market. The obligation is introduced separately for each product category, via a separate delegated act for example for household appliances, mobile phones or ICT hardware. For most categories the date is not yet fixed; the work plan of the European Commission names 2027 as the earliest moment when such acts could be published.
If your company itself designs equipment, has it made or imports it from outside the EU to sell it here, it is quite possible that the obligation will apply to you at some point once your product category has been designated. If you sell or install equipment that another company has already placed on the market, you are generally not a supplier within the meaning of the regulation, but you will still have to deal with the passport: as a buyer who must be able to pass it on, or as a party who may itself be asked for it by a customer or supervisory authority.
Who the obligation is intended for
The regulation places the obligation on the party responsible for placing a product on the market: the manufacturer, or in the case of products from outside the EU the importer who first places it on the market in the Union. That party compiles the passport, or has it compiled, and ensures that the QR code is placed on or with the product. Exactly who qualifies as a supplier depends on the role a company plays in the chain; that is a question in itself and is dealt with separately elsewhere on this site. read back the explanation per role in the chain
When it affects your sector
Because the regulation is elaborated per sub-category, the obligation does not apply to all electronics and ICT at once. A manufacturer of washing machines may be subject to an earlier delegated act than a laptop supplier, and vice versa. As long as no act has been published for a category, there is also no obligation for that category to provide a passport. This does not mean that the time until then yields nothing: the requirements for data, origin and service life that are in the regulation already provide direction on how companies can prepare their administration.
And if you are not a manufacturer or importer yourself?
An installation company that assembles equipment from a supplier at customers' premises is in most cases not a supplier. The same applies to an office that purchases computers and phones for its own use: that is a user, not a party that compiles the passport. Nevertheless, the subject can land on your desk. A customer can ask for the passport of equipment you have placed. A supplier can ask you to pass data on to the next link in the chain. And when selling second-hand equipment, the question can arise who at that time must be able to show which information. None of these situations automatically makes your company a supplier, but they are reason enough to know where you stand in the chain.
What you can do now
For most SMEs at this moment it is mainly a matter of knowing when the subject comes up again, and not of already taking measures for obligations that do not yet apply. A good starting point is to find out which product category your main equipment falls into and whether a delegated act has already been announced for it. Those who are unsure whether their own role is that of supplier, distributor or user can have that tested with a few questions. get an indication with a few questions whether this affects your company
It is good to keep in mind that the introduction proceeds per category and that an act for your sector may still be missing now. As soon as it is published, the situation changes, and it is advisable to look again at your own role and the associated deadlines.
Where you can find this
The official text of the regulation and the Commission's work plan are publicly available, and the source is indicated for each topic in the knowledge base so you can trace back where an explanation is based on. For those who prefer to first get a broader picture of how elektropas.com works and where the information comes from, there is an explanation of the working method. read how we compile information and where it comes from
Are you uncertain whether your company needs to prepare for anything at this moment, or would you first like to see which questions are relevant to your situation? Take the free quick-scan or browse through the topics in the knowledge base; for an explanation of your own position in the supply chain, a lawyer or the competent supervisory authority remains the appropriate point of contact.