The digital passport, explained without jargon.
Six short answers. Tap each one to read it.
01What is a digital product passport?
A digital record of the product, one QR scan away.
It is a digital record with a product's information: what it is, what it is made of, who is responsible for it and how it is repaired or recycled. You reach it by scanning a code, usually a QR code, on the product or its label.
- Product
- QR code
- Digital record
- Each person sees what applies to them
What is it for?
So that customers, repairers, recyclers and authorities can find reliable product information in one place, throughout the product's life. The European Union is rolling it out sector by sector.
The QR code is just the door
Scanning the code is instant. The hard part is what lies behind it: gathering correct data, storing it in a common format and keeping it up to date.
An example: an industrial battery
Its passport will show, among other things, who makes it, the model, what it is made of, its capacity and data on its durability. Part of it will be public and part only visible to those with a legitimate interest, such as recyclers or authorities.
Each sector, its own rules
There is no single data list for all products. Each sector has its own rule, with its own data and dates. Batteries come first: from 18 February 2027 for three types of batteries.
02How do you prepare a passport?
Seven steps, from the product to the published record.
A passport does not start with the QR code. It starts with knowing what you have to disclose and having that information at hand.
1. Know which rule applies
What the product is, which category it falls into and your company's role: whether you manufacture, import, assemble or distribute.
2. List the data
The rule says which data must be provided. Keep what is already mandatory apart from what comes later.
3. Gather the information
Some of it you hold; some your suppliers hold. Ask for it, review it and note what is missing, without filling gaps with guesses.
4. Keep each data point with its proof
Every data point should come with the document that backs it up: a test report, a certificate or a declaration.
5. Publish the record and the QR code
The record is published in a common format and linked to the product's code, as the rule requires.
6. Register and decide who sees what
Some rules require registering the passport in an official registry and separating public from restricted information.
7. Keep it up to date
If a data point changes, the passport is updated. You need someone responsible and a simple procedure.
03Which companies are affected?
Who is responsible for the passport and who only supplies data.
Many companies take part in the chain, but not all have the same obligation. Usually the company that sells the product for the first time in the EU is responsible.
Manufacturers
If you make the product and sell it in the EU, the passport is usually your responsibility.
Importers
If you bring the product from outside the EU, you may be the one responsible, even if you did not make it. For batteries, this also covers products with a battery inside.
Assemblers and modifiers
If you assemble battery packs or integrate components and sell the result under your name, you may be considered the manufacturer.
Distributors
They usually do not create the passport, but they have their own checking obligations for what they sell.
Suppliers
They provide data only they hold, such as cell or material data. Often their customer asks for it by contract, rather than the law directly.
Companies outside the EU
If you sell into Europe, your customer or importer will ask you for the data. Having it ready is a commercial advantage.
04When will it be mandatory?
Each sector has its own date; batteries come first.
There is no single date. Each type of product has its own rule, and some are still being prepared.
Batteries: 18 February 2027
From that date, a passport is required for electric vehicle batteries, batteries for e-bikes, e-scooters and other light vehicles, and industrial batteries above 2 kWh. The 2 kWh threshold only applies to industrial batteries. Source: Regulation (EU) 2023/1542.
The general ecodesign rule
Regulation (EU) 2024/1781 allows a passport to be required for many other products, but each group needs its own implementing rule, with its own data and dates.
Other sectors
Detergents: from 23 September 2029. Toys: from 1 August 2030. Construction products: 18 months after the rule for each family is adopted. Textiles, furniture, tyres and others: their rules are still in preparation.
Certain versus expected
A rule published in the Official Journal with an application date is mandatory. A work plan or a proposal is a forecast, and its dates may change.
Each product, its own date
Each type of product has its own rule and date. Follow the one for your product.
- 2024
Ecodesign
The general ecodesign rule (Regulation 2024/1781). Each product group then needs its own rule.
- 18 FEB 2027
Battery passport
Electric vehicle, light vehicle and industrial batteries above 2 kWh.
- BY SECTOR
Other products
Detergents in 2029 and toys in 2030. Construction, textiles and others, according to their rule.
05What information does a passport contain?
The main blocks of data, explained without jargon.
Each rule sets its own list. These are the blocks that recur, with batteries as the example.
Who and what
The identification of the product and the model, and the details of the responsible company.
What it is made of
Its materials and, where present, hazardous substances. For batteries, for example, their chemistry.
How it performs and how long it lasts
Technical performance data. For batteries, capacity and durability data.
How it is dismantled and recycled
Information to repair, dismantle or recycle it, mainly intended for professionals.
Data that comes later
Some data, such as the carbon footprint or recycled content of batteries, will be required later, once their calculation rules are adopted.
Each data point, with its proof
What is published must be backed by documents. Part of it is public and part is only visible to those with a legitimate interest, such as recyclers or authorities.
06Digital passport: frequently asked questions
Short answers to companies' first questions.
What we are asked most, in a few lines.
Your questions, answered
Do all products need a passport?
No. Only those whose rule requires it, and from the date that rule sets. Batteries come first, from 18 February 2027.
Is a QR code enough?
No. The QR code only leads to the record. What matters is that the information behind it is complete, correct and up to date.
Who has to create the passport?
Usually the company that sells the product for the first time in the EU: the manufacturer or the importer. For batteries, also whoever starts using one on their own account.
Can we start now, even if details are missing?
Yes, and it pays to: gathering supplier data takes months. What is not yet defined is left ready to adjust later.
Are my suppliers required to give me the data?
Not always. Often the obligation is yours and you will need to request it by contract. That is why it pays to ask early.
What if a data point is missing?
It is recorded, requested from whoever holds it and backed by the document that proves it. It is never filled in with guesses.
Do you work with companies outside Spain?
Yes. With companies selling in any EU country.
Tell us what you sell and we'll tell you where to start.
We reply by email with whether it applies to you and where to start.