A customer asks when we will have a digital product passport

The digital product passport is a tool of the Ecodesign Regulation (EU) 2024/1781, not a stand-alone duty. The regulation establishes the passport (Article 1(1)) and lets the Commission set ecodesign requirements by delegated act for product groups (Article 4(1)). Where those information requirements include a passport, products can only be placed on the market or put into service if a passport is available in line with the delegated act, and its data must be accurate, complete and up to date (Article 9(1)). Delegated acts normally apply no earlier than 18 months after their entry into force (Article 4(4)).^[1]

The delegated act fills in the detail: the data from Annex III, the data carrier and its position, whether the passport is kept per model, batch or item, how it is shown to customers before purchase, who may access and update which data, and how long it remains available, at least the expected lifetime of the product (Article 9(2)). The passport is connected through a data carrier to a persistent unique product identifier, uses open and interoperable standards and may not store customers' personal data without their explicit consent (Article 10(1)).^[1]

Some preparation is the same for every product group. The economic operator placing the product on the market makes a back-up copy available through a passport service provider (Article 10(4)), gives dealers and online marketplaces a digital copy of the data carrier or identifier within five working days of a request (Article 10(3)), and uploads the unique identifiers to the Commission's registry, which was to be set up by 19 July 2026 and also stores the battery identifiers (Article 13(1) and (4)). Manufacturers and importers check that a passport, including the back-up copy, is available before placing the product on the market (Articles 27(1)(c) and 29(2)(c)).^[1]

Batteries go first. From 18 February 2027, each LMT battery, each industrial battery with a capacity greater than 2 kWh and each electric vehicle battery placed on the market or put into service has a battery passport (Battery Regulation Article 77(1)). It is reached through a QR code, kept accurate by the operator placing the battery on the market, and its unique identifier is uploaded to the registry under Regulation (EU) 2024/1781 (Article 77(3), (4) and (10)).^[2]