Foundations
What problem digital product passports are meant to solve
The people who handle a product after the sale cannot find out what it is made of. A digital product passport is the European answer to that gap.
A digital product passport is meant to solve one problem. A buyer, a repairer, a recycler and a customs officer each need to know what is inside a product. After the sale, none of them can get that data.
The European Union wants products to last longer. It wants people to repair them and to recycle them. None of that happens without the product data.
A passport attaches that data to the product itself, in a form a machine can read. A code on the product leads to the data.
Here is why the problem reaches you before any law does. Your European buyer meets it every week, and the buyer does not wait for the European Commission. A buyer can make the data a condition of purchase years before a rule covers your product group.
The information exists, and it stops at the sale
A merino jumper leaves a New Zealand mill with a full record behind it. The fibre content sits in a specification. A test result sits with the manufacturer. A certificate sits in somebody's inbox. The current version of each item is hard to find, even inside the company that made the product.
The buyer receives the product, but not the record.
The law is the Ecodesign for Sustainable Products Regulation (ESPR), Regulation (EU) 2024/1781. It moves companies away from the make, use and dispose model. It pushes them towards products that last longer, and that a person can repair and recycle. GS1 described that purpose at a public webinar of 5 May 2026. See where the idea came from for the policy behind that purpose.
A repairer cannot order a part that no document names
A repairer works on a product years after the sale, frequently in another country. That person needs to know what is inside the product and which part fits it.
European law names that reader, for one product group. The battery regulation, Regulation (EU) 2023/1542, gives access to any person with a legitimate interest. It also requires a new passport when somebody repurposes a battery. The battery passport duty starts on 18 February 2027.
A recycler cannot sort a material that nothing declares
A recycler receives an e-bike battery at the end of its life. That recycler needs the composition of the pack before it can sort the materials.
The battery passport lasts until that moment. Article 77(8) of the battery regulation states that the passport "shall cease to exist after the battery has been recycled".
Warning: the three groups below are not ranked. The second group and the third group overlap, and neither one contains the first. See who can see what and recyclers and repairers.
The law also decides who may read the data before that moment. Article 77(2) names three groups of readers:
- the general public
- notified bodies, market surveillance authorities and the Commission
- any person with a legitimate interest
A buyer cannot compare two suppliers who answer different questionnaires
Every customer asks for the same facts in a different form. A supplier fills in one spreadsheet for one brand, then a different spreadsheet for the next brand. Nobody can compare the two answers, and the supplier does the work twice.
Ingmar Hensbergen of HEMA, a Dutch company, described the cost at the same GS1 webinar:
If I have my own language at HEMA and H&M has his own language then we have to explain a lot to our same suppliers, and that takes a lot of time and effort.
ESPR Article 14 answers this problem directly. It requires a publicly accessible web portal where stakeholders search and compare passport data. See the EU web portal.
A customs officer cannot check a claim that sits in an email
A customs system reads structured data. It cannot pull the fibre content of a jumper out of a page layout, and it cannot open an email thread.
The gap is real today. At the same webinar, Eleanor Gayle of GS1 described how upstream apparel suppliers work now: many share spreadsheets, or scans of paper documents.
ESPR Article 15 requires the registration identifier to go to customs. That article applies only once the registry is operational, and only to products that a delegated act covers. See market surveillance and customs.
The EU answer is to put the data on the product
The regulation puts its answer in five places.
| Provision | What it does |
|---|---|
| Article 9 | Makes a passport a condition of market access for a covered product |
| Annex III | Puts a data carrier and a unique product identifier on the product, under the ISO/IEC 15459 series, parts 1 to 6 |
| Article 10(1)(c) | Allows those standards, or equivalent ones, until the Commission publishes the references of harmonised standards |
| Article 10(c) | Keeps the data with the operator, or with a passport service provider |
| Article 14 | Requires a public web portal for search and comparison |
ESPR names no vendor scheme. A search of the full regulation returns no hit for GS1, for Digital Link, for IEC 61406 or for the digital object identifier (DOI). A supplier can state the opposite. Ask that supplier to name the article.
The Commission also runs a central registry, which became operational in July 2026. Warning: the registry holds identifiers, not your product data. No operator has an obligation to upload data yet, because no delegated act applies. A registration also proves nothing. Article 13(5) states that the registry's communication "shall not be deemed to be proof of compliance with this Regulation or other Union law". See the EU registry and how a passport works.
The law reaches your product only through a delegated act
ESPR is in force. It still creates no passport duty for any specific product. The duty arrives only when the Commission adopts a delegated act for that product group. See what a delegated act is.
| Item | Status |
|---|---|
| ESPR entry into force | In force, 18 July 2024 |
| ESPR delegated acts adopted for any product group | None, as at 14 August 2026 |
| Battery passport duty, Regulation (EU) 2023/1542 | Applies from 18 February 2027 |
Article 4(4) sets the transition. A delegated act applies no earlier than 18 months after it enters into force, except in duly justified cases.
Warning: the first category below carries no size limit. Some summaries call this a rule for large batteries. An e-bike battery is small, and it is covered. The Commission web page on digital product passports writes "certain types of batteries, including", and that list is open. See batteries and how to read the timeline.
The battery duty covers three categories:
- each light means of transport (LMT) battery, such as an e-bike battery
- each industrial battery with a capacity greater than 2 kilowatt hours
- each electric vehicle battery
A New Zealand exporter meets the problem before the rule
Ingmar Hensbergen made a second point at the same webinar. He said that HEMA already buys products that will need a passport, so the company must act fast. The purchase decisions come before the delegated act, and the data request comes with them.
That is how the demand reaches New Zealand. It arrives as a purchase condition from a customer, not as a letter from a regulator. If you supply a component, your customer passes the request to you, because they must answer for the finished product. See if you supply a component.
The Ministry of Foreign Affairs and Trade gives the same advice in its one report on the subject, of October 2025. It tells you to prepare for the passport. Set up systems that record your product data and report it. Read the report. It also says the work costs money, and it gives no figure. See what New Zealand agencies have said.
Nobody has published what a passport saves
No published pilot gives a cost, a time, an error rate or a benefit figure. CIRPASS-2, an innovation project funded by the European Commission, claims feasibility and interoperability across 13 pilots, but it publishes no numbers.
What this site searched, and what came back, is listed in what this site does not know.
Warning: the figures in circulation measure something else. GS1 UK reports less food waste and better store productivity at Woolworths Australia, in an interview with the Institute of Grocery Distribution. That result comes from 2D barcodes that carry batch and date data. No passport was involved.
So judge this work by the problem it solves. No published figure measures the saving. Find out how long your own company takes to produce the current record for one product. That record is the specification, the certificate and the origin evidence. If the answer is a day of searching, the problem on this page is already yours.