What information must be in a Digital Product Passport?

A digital product passport must contain information about the manufacturer, product, applicable EU regulations and directives, harmonised standards, and other details. This guide explains what information you may need to include based on Annex VI of the Toy Safety Regulation.

While the exact format and information may differ for other products, it gives you a relatively clear picture of what you must include in a digital product passport.

Unique product identifier

Manufacturers are responsible for uploading the unique product identifier in the digital product passport registry. The unique product identifier must also be present in the digital product passport.

The format of the unique product identifier is specified in Article 2 of the Ecodesign for Sustainable Products Regulation:

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‘unique product identifier’ means a unique string of characters for the identification of a product that also enables a web link to the digital product passport;

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Manufacturer information

The following manufacturer information must be present in the digital product passport:

• Manufacturer company name
• Manufacturer address
• Manufacturer’s authorised representative (if any)
• Unique operator identifier

Non-EU companies selling in the EU will likely need to specify their authorised representative in the digital product passport.

Further, the unique operator identifier is also to be uploaded to the digital product passport registry. The format is also specified in Article 2 of the Ecodesign for Sustainable Products Regulation:

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‘unique operator identifier’ means a unique string of characters for the identification of an actor involved in a product’s value chain;

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It should also be noted that a manufacturer is not necessarily the company operating the factory where the product is made. Companies that have products manufactured by third-party suppliers are often classified as manufacturers.

Economic operator

In addition to manufacturer information, the following economic operators, defined in the Market Surveillance Regulation, may also need to be specified:

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(b) an importer, where the manufacturer is not established in the Union;

(c) an authorised representative who has a written mandate from the manufacturer designating the authorised representative to perform the tasks set out in paragraph 3 on the manufacturer’s behalf;

(d) a fulfilment service provider established in the Union with respect to the products it handles, where no other economic operator as mentioned in points (a), (b) and (c) is established in the Union.

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More specifically, the digital product passport must contain their company name, address, and unique operator identifier.

Product information

The product must be identifiable and traceable within the digital product passport. While this section is short on detail in the Toy Safety Regulation, it is possible that this could be included:

• Product model
• Article number/SKU
• Batch number format

Part II of Annex VI also states that an image or drawing of the product can be included.

Commodity code

The commodity code, as specified in the Council Regulation (EEC) No 2658/87, must be included in the digital product passport.

EU regulations and directives

The digital product passport must include a list of EU regulations and directives that the product complies with. For toys, this must at a minimum list the Toy Safety Regulation – but could also include other regulations.

For example, an electronic toy containing a battery may also need to comply with the following:

• RoHS Directive
• EMC Directive
• Low Voltage Directive
• Radio Equipment Directive
• Battery Regulation

Harmonised standards

The harmonised standards that the product complies with must be specified in the digital product passport. For toys, this likely includes the following standards:

EN 71-1: Safety of toys – Part 1: Mechanical and physical properties

EN 71-2: Safety of toys – Part 2: Flammability

EN 71-3: Safety of toys – Part 3: Migration of certain elements

Keep in mind that additional harmonised standards may also apply.

Further, you may also need to list non-harmonised EN standards or other technical specifications the product complies with.

Notified body information

The information of the notified body must be included if you have followed a conformity assessment procedure that requires one. The following information must be present:

• Notified body name
• Notified body number
• Certificate number

CE mark

The CE mark must be included in the digital product passport.

Substance information

Annex II specifically mentions that certain fragrance substances must be specified.

Communication channel

The manufacturer must provide contact points for consumers to report safety and compliance issues. The following communication channels are mentioned:

• Phone number
• Electronic address (possibly a website and email)
• Dedicated website contact point

Safety Business Gateway link

The digital product passport must include links to the Safety Business Gateway, where customers can report dangerous products to the authorities.

Warnings and instructions

Some products require safety instructions, warnings and instructions of use. When this is the case, these should be included in the digital product passport.

FAQ

Does the digital product passport information differ between products?

At the time of writing, the only definitive list of information to be included in a digital product passport is provided in the Toy Safety Regulation, which only applies to toys. It is likely that the format of the digital product passport will differ to some extent for other products.

Where can I find the digital product passport information required for a certain product?

The required information for toys can be found in the Annex VI of the Toy Safety Regulation.

The Ecodesign for Sustainable Products Regulation also provides general information on what should be included in a digital product passport. That said, the specific details are provided in delegated acts.