Anyone preparing for the digital product passport soon asks themselves which documents need to be included. The short answer: the passport collects information that largely already exists, such as the EU Declaration of Conformity, the technical file, data on materials and components, and instructions for repair and end-of-life. In most cases, the passport does not require new documents to be written, but rather for existing information to be brought together and disclosed in a fixed, digital manner via a QR code.
Which documents are exactly required varies by product category. For electronics and ICT equipment, the European Commission lays this down per subcategory in a delegated act, and these have not yet been published for most categories. What can already be mentioned are the types of documents that recur each time, regardless of which specific device is involved.
What data does the passport exactly request
A digital product passport revolves around a number of fixed building blocks: the identification of the product and of the manufacturer or importer, technical documentation as is also drawn up for CE marking, information on materials and substances used, data on energy consumption or performance where applicable, and instructions for repair, disassembly and recycling. For anyone setting this out for the first time, it helps to look at each component to see who has the information in-house: your own technical department, the manufacturer abroad, or a supplier. In the knowledge base this is elaborated further per topic. per situation tailored overview of what needs to be included.
Documents you probably already have
These are documents that many companies already prepare for other obligations. The EU Declaration of Conformity and the technical file that go with CE marking, safety data sheets, and documentation drawn up to comply with RoHS or REACH, provide a large part of the basis. Warranty and repair information that is already provided to customers is also usable material. So it is not a matter of starting from scratch, but of checking what you already have and where it is located.
What is still missing at most companies
The detail that comes to the fore most on this topic is the level of detail itself. Existing technical files often describe a product in broad strokes, whereas a product passport may request information per component or material, down to the level of specific parts. The same precision applies to provenance information: whereas a declaration of conformity often suffices with a statement that standards have been complied with, a passport may request tracing via which supplier a particular component was supplied. That is a new type of administration for many companies, even though the underlying information itself is not new.
Who supplies what
With assembled equipment, such as ICT hardware with components from multiple suppliers, not all information is held by one party. It is then important to map out early on which party supplies which part of the puzzle, and with which supplier agreements are needed. Anyone unsure whether a particular document is already sufficient, or wants to see how this works out for their own assortment, can see with a few questions a first indication check.
When this needs to be established
The timing is linked to the ESPR work plan for 2025-2030: delegated acts per subcategory are expected from 2027 onwards, but a fixed date is not yet available for most electronics and ICT categories. Once an act is published, it will be clear which documents are exactly required and within which timeframe. Until then, it is mainly wise to know where the existing documents are located and who manages them, so that it does not become a rush job once the date is fixed. How elektropas.com processes the data from these documents into a passport is explained on the page where the information in the passport comes from.
For your specific situation and to determine which documents are specifically relevant for a particular product or brand, a lawyer or the competent supervisory authority remains the appropriate contact. If you first want to get an impression of what is likely to be involved for your products, the free quick-scan can be a starting point, or you can consult the topics in the frequently asked questions for a broader overview.