One regulation, but not identical implementation everywhere
If you sell electronics or ICT equipment in multiple EU countries, the first reassurance is that the digital product passport stems from one regulation: the ESPR (Ecodesign for Sustainable Products Regulation). A regulation works differently from a directive. A directive must first be transposed into national law by each country, and this often leads to small differences between countries. A regulation, by contrast, applies directly and in the same way in all Member States, without an intermediate step. The substantive requirements for the passport itself — which data it must contain, how long it must remain available, what the QR data carrier must do — are therefore in principle identical throughout the EU.
What can differ is not in the content of the passport but in the implementation surrounding it: which authority supervises it, in which language information for the user must be available, and which other, already existing national obligations remain alongside the passport. These are three separate points, and they are explained one by one below.
The supervisory authority is a different organisation in each country
Market surveillance of product rules is always organised nationally in the EU, even for regulations that are otherwise identical everywhere. This means that the authority that supervises electronics and ICT equipment in the Netherlands is not the same as the authority in Germany, Belgium or France. Each Member State appoints its own supervisory authority and determines how it arranges these checks itself. This does not change the content of the passport for your business, but it is good to know that an inquiry or inspection in another country goes through a different organisation than you are used to in the Netherlands. Which authority this is exactly, and how it operates, each country announces separately.
Language: no crystallised rule yet per product category
A question that comes up regularly: must the information in the passport be in the language of each country where the product is sold? With many existing EU product rules, the idea is that information for the end user must be comprehensible, and in practice this is often translated into the language of the country of sale. For the digital product passport, this will be further developed per product category in the delegated acts that the European Commission still has to publish. At this moment, therefore, it is not yet definitively established how language will be regulated precisely for electronics and ICT equipment. Once a delegated act for your product category is published, that is the moment to check this specifically, for example with a lawyer or via the official text.
National obligations remain alongside the passport
The digital product passport does not replace existing national registrations. A well-known example is producer registration under the WEEE rules for electrical equipment: that registration runs per country via its own register and own conditions, and simply continues to exist alongside the passport. Those selling in multiple countries can therefore face multiple national registrations at the same time, while the passport itself remains a single EU-wide given. This type of overlap between new and existing regulations is precisely the type of question for which the knowledge base addresses per situation, so you don't have to figure out yourself which obligation comes from which framework.
And outside the EU?
The digital product passport is an EU instrument. If you also sell outside the European Union, the rules of that country or region apply there, which are separate from the ESPR. Other countries may have their own labelling or information requirements, or may not yet have a comparable system. For exports outside the EU, it is therefore important to review those rules separately; the digital product passport does not address this in itself.
What this means in practice
For a company operating in multiple EU countries, the key point is that the content of the passport does not change per country, but the environment around it does: a different competent authority, possibly different language requirements once these are established per product group, and national registers that continue to exist alongside the passport. If you want to get a clear picture for your own product group and sales markets regarding which components are uniform EU-wide and which are country-specific, it helps to go through this systematically rather than answering separate questions per country.
Curious how this applies to your products and sales markets? Take the free quick-scan and see in a few questions where you stand, view how we collect the data and where it comes from, or browse through the answers to frequently asked questions.