What is the digital product passport?

To contribute to a sustainable development transition, the European Union is embracing the potential of digitalisation. With the digital product passport, consumers have access to different information, aiming to make products durable, reliable, reusable, and easier to repair and maintain, consequently reducing the product’s life cycle impact. Essentially, the digital product passport is a set of data that includes information specific to one product, accessible through a data carrier, such as a QR code.

The introduction of the digital product passport is one of the requirements of the Proposal for Ecodesign for Sustainable Products Regulation (ESPR), published in 2022. The Proposal is currently under negotiations by the Council and the European Parliament.

How the digital product passport will work

The proposed Regulation would apply to any physical goods, including components and intermediate products. Only a few products are excluded from the ESPR scope: food, feed, medicinal products for human use and veterinary use, and plants, among others. Toys, electronics, construction products, PPE, marine equipment, machinery equipment, and many other products will have to have a digital product passport. Most importantly, the introduction of the digital passport concerns both products manufactured in the EU or imported into the EU.

The passport must be freely accessible, and the economic operator responsible for the passport’s creation (or any operators authorised to act on their behalf) must store the data included in it. Together with improving usability and durability, the product’s passport will bring many benefits to manufacturers, such as:

  • Better post-market traceability, recall management, and incident reporting.
  • Enhanced repairability and circularity.
  • Improved end-user or consumer communications.
  • Easier information sharing on the product (e.g., digital instructions for use and warranty information).

Elements to include in the product passport

Chapter III of the proposed ESPR addresses the specificities of the digital product passport and its requirements. Overall, a digital product passport should include the following elements:

  • Product model, batch, or item.
  • Connection to a unique product identifier via a data carrier, which will enable product’s identification. The product must display the data carrier directly on the product, the packaging, or on the documentation accompanying the product (e.g., the instruction for use).
  • All information must be in an inter-operable format and be machine-readable, structured, and searchable.

Key concepts: unique product identifier, data carrier, and passport registry

Efficient product identification is fundamental to enable traceability across the supply chain. For this purpose, the digital product passport is linked to a product identifier, a unique string of characters. Where appropriate, the passport should also allow to track economic operators and manufacturing. The passport is accessible through a data carrier, such as a watermark or a QR code. The data carrier should be displayed directly on the product, the packaging, or the documentation accompanying the product (e.g., the instructions for use) and remain accessible throughout the product’s life cycle. However, some exceptions are possible depending on the product’s size or use. The unique product identifier and the data carrier must comply with standard ISO/IEC 15459:2015.

All information included in the product passports will be stored in a registry maintained and set up by the European Commission. This will allow the verification of the passport’s authenticity, improve the efficiency and effectiveness of market surveillance and customs controls, and avoid disproportionate administrative burdens for economic operators.

The current Regulation text is not final. PRODlaw Team will publish updates and news on the Ecodesign for Sustainable Products Regulation (ESPR).

PRODlaw is a free-membership project powered by Obelis, a consultancy and representation services leader in different world regions. Contact us if you want to know more about regulatory requirements to sell your products in Europe.

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