Digital Product Passport: why manufacturers should start with their data now

A Digital Product Passport is quick to produce: a data record, a web address, a QR code on the product. The difficulty sits one level down. Where does the information on materials, substances, origin and repair come from? Who maintains it, who approves it, and where will it still be in ten years? For most manufacturing companies, the data foundation determines the effort, not the technology. Companies that start today will have less work later, even if the delegated act for their product group has not yet been adopted.

Legal framework

Ecodesign Regulation (ESPR), Regulation (EU) 2024/1781

First obligation

Battery passport from 18 February 2027

EU registry

live since 20 July 2026

Standards

six harmonised standards since July 2026, incl. EN 18219 and EN 18220

The passport is only as good as the data behind it

The Commission sets out what a product passport must contain in a separate delegated act for each product group. Typical items are materials and components, substances of concern, recycled content, carbon footprint, repair, spare parts and disposal. Almost none of this is new to a manufacturer. What is new is that the information must be complete, up to date, machine-readable and clearly assigned to a specific product.

In practice, the data is spread across many systems: master data in the ERP, technical attributes and bills of materials in the PLM, product descriptions in the PIM, certificates and test reports in document management, material details in supplier data sheets and a great deal in Excel lists. That leads to familiar problems: missing material details, expired certificates, the same attribute spelled three different ways. Internally, this often goes unnoticed. In a product passport accessed by customers, recyclers and market surveillance authorities, it does not.

Material data is the most demanding part

For manufacturers, the biggest gap is usually in materials. Material data sheets arrive as PDFs, in different formats and at different levels of detail. To turn them into passport data, they have to be converted into structured, machine-readable records and linked to the bill of materials: which material is in which component, in what quantity, with which substances and at what concentration?

Bringing material data, bills of materials, supplier information and regulatory requirements together in one place pays off twice. The product passport can be derived from it, and the same data helps in development, purchasing and simulation. Where suppliers do not provide values, reference data based on typical industry values can close a gap for the time being. It should, however, be labelled as such and later replaced with actual supplier data.

A question of architecture, not just sustainability

The product passport is often assigned to the sustainability or compliance department. Technically, it is a task for the entire IT landscape. Two points are easily underestimated.

• Unique identifiers: a product passport is only as reliable as the key used to find it. With Implementing Decision (EU) 2026/1736, the Commission recognised six standards for the product passport as harmonised in July 2026, including EN 18219 for unique identifiers and EN 18220 for data carriers such as QR codes, Data Matrix or RFID. Applying them is voluntary. Those who do, however, benefit from a presumption of conformity with Articles 10 and 11 ESPR.
• Long-term availability: the passport must remain accessible for as long as the delegated act for the product group requires. For industrial goods and batteries, that means many years, often longer than a software project or the platform it runs on. Web addresses should therefore not be tied to a campaign domain or a single provider. Article 10(4) ESPR also requires a backup copy to be held by an independent third-party service provider.

Why it pays to start now

As a rule, at least 18 months pass between a delegated act entering into force and its application. That sounds like plenty of time. But anyone who has ever collected material data across several tiers of suppliers knows that the responses alone can take months. On top of that come the data model, system integration, approval processes and testing.

Most of the groundwork does not depend on the details of the delegated act. Which materials a product contains, which supplier provides them and where the certificate is kept are things a company needs to know anyway. Much of this information is already required today, for example for the Packaging and Packaging Waste Regulation (PPWR), for REACH disclosures or for CBAM reports. Structured properly once, it can be used many times.

There is also value beyond compliance. Well-maintained product data shortens responses to customer enquiries, makes tenders easier and makes sustainability claims verifiable. The passport itself can provide spare part and repair information, take load off customer service and create a direct link to the customer after the sale.

Five first steps for manufacturing companies

• Check whether you are affected: which products fall into groups for which a passport is planned? Batteries, iron and steel, textiles, aluminium and tyres are at the top of the Commission’s working plan. Suppliers to these industries should also expect data requests.
• Take stock: which product, material and evidence data exists in which system, and how complete and current is it?
• Assign responsibility: who maintains, checks and approves which group of data, and which system takes precedence in case of doubt?
• Involve suppliers: which information is needed from whom, in which format and how often is it updated?
• Plan identifiers and systems: provide for unique product identifiers in line with EN 18219 and design interfaces so that the passport is generated from existing data rather than maintained by hand.

More in the IHK webinar on 27 October

In the free webinar “Digitaler Produktpass – was ist zu tun?” (“The Digital Product Passport – what needs to be done?”) hosted by the IHK Mittlerer Niederrhein, the chamber of commerce for the Lower Rhine region, Oskar Cornelissen, co-founder and Chief Legal Officer of Reguly, addresses exactly these questions: which requirements apply, how companies can prepare their product data and systems, where product digitalisation adds value beyond compliance and where to begin. The webinar takes place online on Tuesday, 27 October 2026, from 10:00 to 11:00 CET, and is held in German. No prior knowledge is needed, and there will be time for questions at the end.