What is a digital product passport for electronics?
A digital file that stays attached to the product
A digital product passport is a digital file containing data about a product, which remains linked to that specific product or product group via a data carrier — usually a QR code — from production to recycling. The passport contains information that is now often fragmented: on materials, repair, spare parts, origin and environmental impacts. Where a manual or declaration of conformity stands on paper or as a separate pdf, the passport is intended as a single point of reference that repairers, recyclers, supervisory authorities and sometimes also the consumer can consult by scanning the code. The passport does not replace existing mandatory documentation such as CE marking, but in most cases comes alongside it, as an additional, searchable layer.
Per sub-category of electronics, not all at once
The digital product passport does not automatically apply to all electronics at the same time. The ESPR (Regulation (EU) 2024/1781) is a framework regulation: article 9 introduces the passport as an instrument, but which product group will actually have to deal with it and with what content is set out per sub-category in a separate delegated act. For electronics and ICT, this means that for example white goods, mobile phones or other equipment can each receive their own rules, with their own requirements and their own entry date. For anyone importing or manufacturing electronics, this means: until the delegated act for their own product category is published, there is no concrete obligation arising from this passport. What does already exist are other regulations such as CE marking, WEEE and RoHS — these are separate from the digital product passport and remain fully in force.
No fixed date yet, but a timeline
There is no set date on which the digital product passport for electronics becomes mandatory. The European Commission is working with a work plan for the period 2025-2030, in which the expected timing of a delegated act is indicated per product group. For electronics and ICT equipment, a first delegated act is not expected before 2027; the actual publication and the subsequent transitional period will only then determine the real entry date. Until that act is in place, nothing will change for most electronics importers and manufacturers regarding mandatory documentation. As soon as a delegated act for a sub-category is published, the concrete date will be fixed and will be stated here.
From data collection to QR code on the product
Anyone who wants to engage with this subject now should approach it in a logical order. First, it is important to find out whether a delegated act is already in preparation or published for their own product category — this determines whether and when a concrete obligation arises. After that, it is useful to map out which data about the product is already available: material composition, repair information, warranty conditions, origin of components. Much of that information already exists somewhere in the organisation, but not in a way that is suitable for a digital, searchable passport. The next question is how that data is converted into a passport that meets the requirements of article 10 of the ESPR, how that passport remains accessible for ten years, and how the QR code is affixed to or attached to the product. That last part — hosting and data carrier — is precisely what a platform like this is intended for: the data from the manufacturer or importer is compiled into a passport, hosted for ten years, and provided with the QR data carrier. For import or production practice, this mainly means: start organising product data now, so that when the delegated act is published, you do not have to start from scratch.
The legal basis: article 9 and article 10 ESPR
That the digital product passport exists and what it must broadly contain follows from Article 9 of the ESPR (Regulation (EU) 2024/1781), which introduces the passport as an instrument linked to a product or product group via a data carrier. Article 10 of the same regulation sets out the requirements the passport must meet: how the data must be accessible, who may access it, and how long the passport must be maintained. Both articles form the general framework; the specific implementation per product group — including that for electronics and ICT — follows from the delegated acts that the Commission establishes per subcategory.
What to do now
Anyone who imports or manufactures electronics can now begin inventorying product data that could later be included in a passport — material, origin, repair data — and monitor when a delegated act is published for their own product category. Once that act is in place, the specific date and content will be listed here.
What this is based on
- Regulation (EU) 2024/1781 (ESPR), article 9 (digital product passport)
- Regulation (EU) 2024/1781 (ESPR), Article 10 (requirements for the digital product passport)
The regulation itself is on EUR-Lex. We provide references per statement; you do not have to take our word for it.
What you must concretely do
What is expected of you
The digital product passport is, as described in Article 9 of the ESPR (Regulation (EU) 2024/1781), a collection of product data made accessible via a data carrier (a QR code or equivalent) to those who are entitled to it. The passport itself is not a separate document, but a set of data attached to a specific product or product model and which must remain available throughout the lifespan of that product. Article 10 of the ESPR (Regulation (EU) 2024/1781) describes the requirements that these data and the technical setup must meet. What this means in concrete terms breaks down into a few distinct obligations.
Submit data correctly and completely
A company that places electronics or ICT equipment on the market supplies the product data that will appear in the passport. For an organisation with 10 to 100 employees, this usually means that data that already exists in various places — in a technical file, with the supplier, in a quality system — must be brought together and structured for the first time. Which data exactly differs per product category; which data goes into the digital product passport for electronics goes into further detail.
A functioning data carrier on the product
The QR code or equivalent carrier must be placed on or with the product and must actually lead to the correct, current data. This is more than just sticking on a label: the carrier must remain linked to the passport, even if a product is still in use years later. In practice, this means a company needs a way to have that link hosted and maintained, not just at the moment of sale.
Control access for the right parties
Not everyone who scans the QR code needs to see the same data. A consumer, a recycler and a regulator may need different information, and Article 10 of the ESPR (Regulation (EU) 2024/1781) addresses who may see which data. For a company, this means thinking about access levels, not one public passport for everyone. See for the division of roles who is allowed to access which data from the digital product passport.
Keep data up to date
A passport is not a snapshot at the time of sale. If a product model changes, or if new information becomes available (for example about repair or spare parts), that change should be reflected in the passport. For companies with a longer product life cycle — such as household appliances or ICT equipment that remains in use for years — this is an ongoing task, not a one-time project. How often and in which cases updating is necessary is described in how current must the data be.
Where things go wrong in practice
A number of situations frequently occur with companies preparing for the product passport.
An importer assumes that the manufacturer in the country of origin will take care of the passport, while the obligation lies with the person placing the product on the EU market. This difference is often discovered too late.
A manufacturer of small household appliances compiles data for one product line and assumes that the same setup automatically applies to another line, while requirements can differ per product category. What is sufficient for one appliance may be incomplete for another.
An ICT supplier places a QR code on the product, but the underlying data is hosted on a system that is not set up to remain available for ten years or longer. Once the platform is dismantled or changes hands, the link disappears.
A company publishes all product data in one publicly accessible passport, including information that is commercially sensitive, because no distinction has been made between what must be public and what is only intended for regulators. See also must I disclose commercially sensitive information about my electronics.
A manufacturer of a device with a built-in battery treats this as one digital product passport issue, whereas separate rules may apply to the battery. That distinction is addressed on my device has a battery, do I need two digital product passports.
What you can document
For companies that want to get organised in advance for what will be required, a number of matters can be established beforehand:
- An overview of which product models fall under their own product category and which data presumably belong to them, as a stepping stone towards the moment when the delegated act for that category has been published.
- A list of where the required product data are already documented (technical file, supplier declarations, quality system), so they do not need to be collected again.
- Agreements with suppliers and sub-suppliers on who supplies which data and when, especially for products consisting of multiple components from different parties.
- An internal agreement on who is responsible for keeping digital product passport data up to date following changes to a product.
- A distinction between data that can be public and data that are intended only for supervisory authorities or other specific parties.
Whether, and at what point, these obligations apply to a specific product depends on the delegated act established for that product category. More information on this is available on what is a delegated act and why does it determine what I have to do and on when does the digital product passport become mandatory for electrical and electronic equipment. For the question of whether a specific product or company falls within its scope, does the digital product passport apply to my electrical and electronic equipment is the starting point.
This is not legal advice. This page provides general information about the regulations that this platform covers. We are not familiar with your situation. If you are in doubt about your own case, consult a lawyer or the competent supervisory authority.
Written with AI based on the sources above, checked by a human on 2026-08-22. Is something incorrect? Let us know — corrections take priority.