What is the data carrier of the digital product passport?
The data carrier is the physical or digital identifier on a product, the packaging or the supplied documentation by which someone gains access to the digital product passport of that product. In practice this is usually a QR code, but the regulation also permits other techniques, as long as they work in the same way: scan or read, and are immediately redirected to the correct information.
The data carrier itself contains no product information. It is the key, not the cabinet. Behind the code is the passport with information about origin, materials, repair and origin of components — precisely the part that we host for you at elektropas.com and for which we provide the data carrier, once the rules for your product category have been established.
Why a separate carrier and not a simple label
A standard product label tells what the manufacturer wanted to have printed on it at that time. A data carrier refers to a passport that is online and can therefore be updated: a repair manual can be added to later, a certificate renewed, without the physical product needing to be relabelled. That is the essence of the digital product passport: the information is alive, the label on the product itself is not.
Supervisory authorities, repairers, recycling companies and buyers must reach the same, up-to-date information with the same code. That is why the regulation sets requirements for the data carrier: it must remain readable and functional throughout the entire lifetime of the product, and be accessible without requiring an account or paid app.
What is already established and what is not
That a data carrier must be provided is established. How it looks exactly, where exactly it must be placed on the product, and which technical standard it must meet, varies by product category and is determined in the delegated acts that the European Commission publishes for each subcategory. For electronics and ICT these are expected from 2027 onwards; there is no fixed date yet. Once an act for your category has been published, it will be updated on elektropas.com.
What is already evident from the regulation itself is the principle: the data carrier must be durably affixed to the product or packaging, must work without the user having to first install software from one specific supplier, and must still be readable after the product has been in use for years. This latter point is a practical consideration for electronics: a sticker on the inside of a casing that comes loose after a repair no longer meets the purpose.
Who ensures that the data carrier is placed on the product
The responsibility for affixing the data carrier lies with the provider of the passport, usually the manufacturer or importer that places the product on the EU market. What that concept precisely means and when you fulfil that role can be read in the explanation of key concepts in the knowledge base. In practice this means that someone in your organisation, or your supplier of packaging and labelling, must know what the code technically needs to comply with before production starts — not only when the product is already on its way to the customer.
What this practically means for your planning
Because the exact technical requirements per product category are still being determined, it is difficult to make a final choice now for the format or placement of the code. It is, however, worthwhile to map out now which products you place on the market, who in your chain supplies the data, and where in the production process a code can logically be applied later. This way you won't have to catch up on everything in the final months before the obligation takes effect.
With the free product scan in which you see in a few questions where you stand you get a first indication of whether and when your products fall under the regulation. On the page that shows where the data in the passport comes from you can read how elektropas.com technically fills in the link between your data and the data carrier once that becomes relevant for your category. And for individual questions about concepts like these, there is the overview of frequently asked questions.
For your own company's situation, with your specific products and packaging, it remains advisable to consult the official text or a legal professional. Would you first like to get a general picture of what will apply to your products? Then do the free quick scan or browse through the topics in the knowledge base.