Regulation (EU) 2024/1781
For product and sustainability teams working out which products need a digital product passport, and what it has to hold. This page covers what you need to know and ways to avoid running into issues.
What we've seen reported
The Ecodesign for Sustainable Products Regulation (ESPR), Regulation (EU) 2024/1781, sets up the EU Digital Product Passport, a digital record linked to each product by a data carrier, with product groups and data fields left to later delegated acts.1
Last updated October 2026 · General information only, not legal advice. Sources.
What the rules cover
These are the Digital Product Passport requirements the ESPR describes, according to its text, and who each one falls on.1
| Requirement | Where it applies |
|---|---|
| A digital product passport | Products in a group covered by a delegated act are placed on the market with a passport available. |
| A data carrier and unique product identifier | Such as a QR code, physically present on the product, its packaging or accompanying documents. |
| What goes in the passport | Set per product group in each delegated act, at model, batch or item level. |
| Access before purchase, including online | Each delegated act sets how customers reach the passport before buying, including in distance sales. |
| A digital copy of the data carrier | Economic operators placing products on the market: a free digital copy for dealers and online marketplaces, to show where customers can't see the product. |
| Registration in the EU registry | Economic operators: passport details uploaded to the registry the Commission sets up and maintains. |
| The registration identifier at import | At import: the product's unique registration identifier given to customs, which check it against the registry. |
Where it goes wrong
One approved set of product information ends up in many channels, markets and languages. Along the way it gets shortened, translated and reworded, and some versions end up without the warnings or details these rules require.
Aria 8 product passport: 32% recycled steel, passport QR code on pack and listings
How Arbitr helps
Manually review everything? Or do what modern teams do and use AI to check that what you publish matches what you approved.
FAQ
Wherever the same product facts appear. The ESPR describes a passport reached through a data carrier on the product, its packaging or its documents,1 and the figures in it are usually repeated in:
Every published copy of the old figure stays live until someone finds it. Treat the passport as the approved record, list every place each figure is repeated, and update them together. Our packaging compliance page shows how teams keep packs and listings in step with product data.
According to the ESPR text, economic operators give dealers and online marketplaces a digital copy of the data carrier, so customers who can't handle the product can still reach the passport.1 Check each listing and retailer feed carries it, in each market's language, before it goes live.
How it applies to a specific listing is a question for your legal adviser. Where that listing appears across your markets and languages is a question Arbitr answers.
Sustainability and product compliance teams usually own the data, but packaging, e-commerce and marketing publish it, and retailers republish it from your feeds. Claims that quote passport figures are covered on our generic environmental claims page, and related rules are on our product labeling hub.
They come from different laws, though headlines often treat them as one. The battery passport is set by the Batteries Regulation, Regulation (EU) 2023/1542, which the ESPR amends, while ESPR passports are set one product group at a time.1
Most companies do, and it works for the file it reviews, in the language it reviews, before a campaign ships. It doesn't cover what's published afterwards: the market versions, the agency reworks, the sales deck built from the campaign six months later. That's a volume problem, not a failure of your legal team.
