CE marking and the digital product passport answer different questions. CE marking is the manufacturer's declaration that a product complies with applicable safety requirements, and this declaration has existed for years for electronics and ICT equipment. The digital product passport does not replace it, but rather supplements it: it documents what a product is made of, how it can be repaired and what happens to it at the end of its life. Both are mandatory, but they address different aspects and occur at different stages in the process.
The practical difference lies mainly in what you must demonstrate. With CE marking, you declare that a product is safe according to applicable product safety rules, with the CE mark and technical documentation as evidence. With the digital product passport, you provide data on materials, components and circularity, accessible via a QR code on or with the product. The passport does not replace the CE declaration and vice versa: a product can be CE marked without a passport, and soon a product must be both CE marked and have a passport once the obligation applies to the relevant product category.
CE marking: what it already regulates
CE marking consists of a set of requirements that differ per product category, with the core principle that a product must not pose an unacceptable risk to users, for example in terms of electrical safety, electromagnetic compatibility or chemical substances. On this basis, the manufacturer draws up a declaration of conformity and applies the CE mark. These rules have been in place for some time and will not change with the introduction of the digital product passport. They continue to exist alongside each other.
The digital product passport: what it adds
The digital product passport stems from the European Ecodesign Regulation (ESPR) and focuses on different information: what materials a product is made of, which components are replaceable, how repair works and what should happen to the product when it is discarded. This information is intended for repairers, recyclers and supervisory authorities, and for the buyer who wants to know in advance how circular a product is. The obligation applies per product category and is introduced through delegated acts expected from 2027 onwards; for electronics and ICT equipment the exact date has not yet been fixed. As soon as this is known, it will be updated here.
Where the two intersect
The overlap lies mainly in the technical documentation you already maintain as a manufacturer or importer for CE marking. Information about materials, components and composition that you currently record for the declaration of conformity is often also needed for the product passport. This does not mean that a single document will suffice for both purposes: CE documentation is focused on safety, the passport on material flows and repair, and the format in which you submit it differs. Companies that already have their CE file in good order generally have an advantage when collecting passport data, simply because the basic information is already in place.
What this means for your business
For most SMEs importing or placing electronics or ICT equipment on the market, the CE obligation itself does not change. The question that is now relevant is whether and when your product group falls under the digital product passport, and which data you must collect separately for it in addition to what you already have for CE. Supervisory authorities look at something different in both regulations: market surveillance for product safety focuses on CE conformity, while surveillance of the product passport focuses on the availability and accuracy of passport data. Who exactly is responsible and what that surveillance looks like varies per Member State and will be further clarified.
Whether your products already fall under a concrete obligation and which data goes with it is best determined on the basis of the official text and, where necessary, in consultation with a lawyer or the competent supervisory authority. For an initial overview, you can find in the knowledge base by topic how CE marking and the digital product passport relate to each other, or get an indication in a few questions where your products stand. Questions about how elektropas.com processes and stores data are answered on the page about how we handle your data.
If you want to read more broadly about how this is linked to other passport obligations, see the frequently asked questions about the digital product passport or take the free quick-scan to see whether and when this will apply to your products.