Questions and answers
What the Digital Product Passport is
What is a Digital Product Passport?
Regulation (EU) 2024/1781 defines it in Art. 2 (28) as a product-specific set of data containing the required information, accessible electronically through a data carrier. In practice: a QR code sits on the product, and whoever scans it sees a page with the details of this exact product.
Which data goes into the product passport?
Annex III of the regulation sets the frame: unique product identifier, GTIN, commodity code, details of manufacturer and importer, declaration of conformity, instructions for use, materials and substances of concern, repair and disposal information. Which of these become mandatory for your product group is set by the delegated act for that group.
Where does the QR code have to be placed?
Under Art. 10 of the regulation on the product itself, on its packaging or in the accompanying documents. Which of these applies to your product group is set by its delegated act. You receive the QR code from us as a print file for the label, the packaging or the rating plate.
What is the EU registry and what is stored there?
The product passport registry of the European Commission stores the unique identifiers of the passports, not their contents. The passport data itself stays with the economic operator or its service provider. On registration the registry issues a registration identifier, which customs checks on import. We handle the registration, it is included in the price.
Do I have to buy the EN standards on the product passport?
No. The standards only provide the presumption that the requirements are met. The obligations are set out in the Ecodesign Regulation and the Implementing Regulation, both free of charge on EUR-Lex.
Obligation and deadlines
When does the Digital Product Passport become mandatory?
The 1st fixed date is 18.02.2027: from then on, batteries above 2 kWh need a battery passport. For the other product groups the Commission work plan names the year of the delegated act: textiles, tyres and aluminium 2027, furniture 2028, electronics 2029. The obligation applies at least 18 months after the act.
Who does the obligation apply to?
Everyone who places a product of the group concerned on the EU market: manufacturers established in the EU, importers, dealers and distributors selling under their own name. Manufacturers outside the EU fulfil the obligations through an authorised representative in the EU.
Does it apply to small companies as well?
Yes. The Ecodesign Regulation contains no general exemption for small companies, there is no minimum quantity and no minimum turnover. Only the delegated act of a product group can grant individual reliefs.
Does the obligation cover goods already in stock?
The obligation is tied to placing on the market, the first making available on the EU market. For batteries the Battery Regulation says so expressly: it applies to batteries placed on the market from 18.02.2027. Whatever was placed on the market before the date needs no passport retroactively. Goods still in your warehouse on the date and sold afterwards do need one.
What happens if a product has no passport?
Under Art. 9 of the regulation, a product covered by the obligation must not be placed on the market without an available product passport. It loses market access. Customs checks the registration identifier on import. Penalties are set by the member states.
Process and technology
Can I create the product passport myself?
Yes, the regulation allows both: the economic operator runs the passports itself or hands them to a service provider. Running them yourself means: building the passport pages and keeping them reachable for the entire product lifetime, verifying in the EU registry with a qualified electronic seal, registering the passports and keeping a backup copy with an independent third party. That is exactly the work we take off your hands for 260 € per 12 months, go to the order page.
Which file do I need for the order?
Your product list as XLSX or CSV, one row per product. The layout is up to you: you upload the file, we suggest how your columns map to the passport fields, you confirm or change the mapping. If you keep no list, download our template, it contains every column with an explanation and 2 example rows.
What if my file contains errors?
We check every row before the order: missing mandatory details, wrong formats, duplicate identifiers. Every finding is reported with the row number from your file. You only pay once the file passes without findings.
What about product changes?
You upload your updated table through your personal access link from the order confirmation, and we change the affected passports. The address and the QR code on the product stay the same, nothing has to be reprinted. Data maintenance is included in the fee.
I lost my access link. What now?
Open labelpass.eu/zugang.php and enter the e-mail address of your order. The link is sent to that address again immediately.
In which language does the passport have to be?
In the language set by the member state on whose market the product is sold (Art. 7 (8) of the regulation). Selling into several countries means several language versions. That is why you select your target markets when ordering. We create the passport in the official languages of those countries at no extra charge and translate your own texts as well, such as material details and safety information. Before publication we show you every translation. You can change any line and approve with one click, after which the pages go online.
How long does the passport stay online?
At least for the expected lifetime of the product, as required by Art. 9 of the regulation. It even has to stay available if the manufacturer becomes insolvent or ceases to exist. With us every passport stays reachable for 10 years from publication, even if the contract ends earlier.
Do I need my own electronic seal or registry access?
No. The EU registry requires the qualified electronic seal only from whoever verifies as an economic operator and enters the passports. We do that, you need neither a seal nor registry access.
Does your offer cover batteries as well?
Yes, with one limitation. Besides the fixed details, the battery passport requires ongoing values from the battery management system, such as remaining capacity, number of charging cycles and temperature events. No table can supply those, that needs an interface to your system. Talk to us and we will assess the effort for your case.
We are based outside the EU. Can you act for us?
Yes. Anyone supplying from outside the EU needs an authorised representative inside the EU who takes on the obligations and is reachable for authorities. We take on that role in addition to the product passport, under a separate agreement. Talk to us before you order.
Price and contract
What does the Digital Product Passport cost?
With us 260 € for 12 months, including 100 product passports, the QR codes, the entry in the EU registry and the running of the passport pages. Each additional passport costs 0.25 €. 500 passports therefore cost 360 € for 12 months. All prices exclude VAT where applicable.
What does access to the EU registry cost?
No fee is foreseen for registry access. Our fee pays for creating the passports, the registration and running the passport pages.
How long does the contract run?
12 months from the order, cancellable at the end of the term. If the contract ends, the passports already created still stay reachable for 10 years from publication, because you are legally required to keep them available and we have taken that on.
What happens if I want to change provider?
Your product data belongs to you and you receive it as a file at any time, machine-readable per passport as well. Another provider can take over your passports from it. The passport pages already published stay reachable with us, we are bound to that for 10 years.
These answers are general information, not legal advice.