What is the Digital Product Passport and why does it concern your company?
If you operate in the manufacturing, industrial, or distribution sectors, you have likely already heard about the Digital Product Passport. But what exactly does Regulation (EU) 2024/1781 entail, and what obligations does it introduce? In summary: the passport will become mandatory product group by product group through delegated acts applicable at least 18 months after adoption. As of August 2026, no ESPR delegated act has been adopted. A passport is a structured set of digitally accessible data. For batteries it is mandatory from 18 February 2027 under Regulation (EU) 2023/1542. The data are linked to the physical product via a unique identifier, typically a QR code. Regulation (EU) 2024/1781, also known as the Ecodesign for Sustainable Products Regulation (ESPR), does not merely extend eco-design requirements: it introduces a digital transparency obligation throughout the entire supply chain. This is not just about CE marking. It’s about making all official product data — materials, traceability, repairability, sustainability — verifiable in real time by anyone entitled to it: customers, distributors, control authorities, and customs operators.
What must the Digital Product Passport contain according to Regulation (EU) 2024/1781?
The question many quality and compliance managers are asking is: what information will I actually need to provide? Regulation (EU) 2024/1781 stipulates that each Digital Product Passport must include data on materials and components used, origin and traceability along the supply chain, repair and maintenance instructions, presence of hazardous substances, end-of-life disassembly methods, and environmental and sustainability data. All this data must be accessible via a digital support — a QR code is the most probable tool — and must be up-to-date, verifiable, and integral. This is precisely the critical point: simply having the information is not enough. It must always be updated and demonstrable. Today, in most companies, this data is scattered across ERPs, PDFs, emails, and supplier systems. When information is updated in a management system, the QR code already printed on the product continues to point to the previous version. This creates documentary inconsistencies which, once the delegated act for the relevant product group applies, could result in penalties or sales halts.
The problem many companies are underestimating
There’s a question every company should ask itself today: can I demonstrate in 30 seconds that the data associated with this product is official and up-to-date? If the answer isn't an immediate “yes,” it’s time to act. The real challenge of the Digital Product Passport is not strictly technological: it's about document governance. The data exists, but it is fragmented, static, and difficult to update in a coordinated manner. A traditional QR code points to a single PDF file: if that PDF changes, the QR becomes unreliable, or you have to reprint everything. This is why the static document logic is incompatible with the requirements of Regulation (EU) 2024/1781. A dynamic digital container is needed that always maintains the same identifier but updates the content in real-time, tracks every version, and ensures data integrity over time.
How to prepare for the Digital Product Passport with Regulation (EU) 2024/1781
The solution is not to buy new software and start from scratch. It is to adopt an infrastructure that integrates with existing systems and structurally solves the problem of data consistency and updating. Certiblok® addresses this need through QRcube®: a permanent digital container that encloses multiple files and content types in a single, always-updated QR code. The physical code remains unchanged on the product; it is the digital content that evolves. Each update generates a new tracked version, while previous ones remain archived and consultable. Files are encrypted with AES-256, split into 80 shards and distributed on a decentralised cloud; each edit creates a new version, previous versions are retained and activity is logged. The system supports full versioning, traceability throughout the supply chain, integration with ERPs and company management systems, and can host product-linked documents (manuals, declarations and data sheets) to which the passport refers. In practice: printed once, updatable forever. Without reprinting, without changing labels, without losing traceability.
When to start? Before the delegated act for your sector applies
The application of your sector’s delegated act might seem far away, but anyone who has dealt with regulatory compliance processes knows that timelines shrink rapidly. Mapping product data, structuring document flows, integrating systems, and testing the infrastructure takes months. Those who start today have a concrete competitive advantage: they can present themselves to their customers and supply chain partners with an organised, transparent, and reliable system. Preparing the documents before the sector’s delegated act applies makes updates easier. For the product groups covered by applicable rules, the Digital Product Passport is not just a requirement: it is an opportunity for those who want to differentiate themselves in the European market with certified transparency and documented quality.
