A QR CODE IS NOT A DIGITAL PRODUCT PASSPORT: WHAT COMPANIES SELLING IN EUROPE NEED TO PREPARE IN 2026
The Digital Product Passport is becoming one of the most important building blocks of the European product economy. It is designed to make information about products more accessible, structured and reliable across the entire value chain: from manufacturers and suppliers to regulators, repairers, recyclers and consumers.
Yet the discussion around the Digital Product Passport, or DPP, is often oversimplified.
Some companies are told that every product sold in Europe will immediately need a digital passport. Others assume that attaching a QR code to a product is enough. Many are still waiting for final deadlines before starting to organise their product data.
All three approaches miss the real issue.
The European Union has already established the legal framework for the Digital Product Passport under the Ecodesign for Sustainable Products Regulation — ESPR, Regulation (EU) 2024/1781. Product-specific obligations will be introduced progressively, but the direction is already clear: companies placing products on the European market will increasingly need to provide structured, accessible and trustworthy product information.
For businesses, 2026 is therefore not the year to wait. It is the year to prepare.
The Digital Product Passport is already part of EU law
The ESPR entered into force on 18 July 2024. It establishes a framework for setting ecodesign requirements for products placed on the EU market and introduces the Digital Product Passport as a central mechanism for making product information digitally available.
This does not mean that every product sold in Europe already requires a Digital Product Passport. The ESPR is a framework regulation: the detailed obligations for particular product groups will be introduced through delegated acts adopted by the European Commission.
These future requirements may specify, among other elements:
which product information must be included;
whether the passport applies at model, batch or individual item level;
which data carrier must connect the physical product to its digital record;
who can access or update specific information;
how long the passport must remain available.
This distinction is fundamental. The regulatory framework already exists, but the practical obligations for most product categories will be phased in through sector-specific rules.
A Digital Product Passport is not just a QR code
A QR code, NFC tag or other data carrier can provide access to a passport. But it is not the passport itself.
A real Digital Product Passport requires a reliable data infrastructure behind the physical access point. It must be able to organise product information, connect data from different systems and suppliers, manage access rights and keep relevant records available over time.
Depending on the applicable product rules, a passport may eventually include information relating to:
product identity and technical characteristics;
materials and components;
durability, repairability and spare parts;
recycled content and recyclability;
environmental or sustainability performance;
certifications and compliance documents;
end-of-life and recycling instructions.
The challenge is therefore not simply how to display information to a customer. The challenge is whether the company can collect, structure, maintain and prove the reliability of product information throughout its lifecycle.
A QR code can open a page. It cannot, by itself, make the information complete, accurate, interoperable or trustworthy.
What will happen in 2026
One of the most important confirmed milestones under the ESPR is scheduled for 2026.
By 19 July 2026, the European Commission must establish a Digital Product Passport Registry. The Registry will store, at minimum, the unique identifiers required for Digital Product Passports and is intended to support the future operation of the DPP system, including checks by competent and customs authorities.
This is a significant regulatory infrastructure milestone. However, it must not be confused with a universal compliance deadline.
The creation of the Registry does not mean that every product placed on the European market must carry a Digital Product Passport from July 2026. Product-specific obligations will still depend on the relevant delegated acts or sector-specific legislation.
What it does mean is that the European DPP architecture is moving from policy design to practical implementation. Businesses should no longer treat product data readiness as a distant topic.
Which product groups are being prioritised
The European Commission’s Ecodesign for Sustainable Products and Energy Labelling Working Plan 2025–2030identifies several priority product groups for future measures under the ESPR.
These include:
textiles and apparel;
furniture;
mattresses;
tyres;
iron and steel;
aluminium.
The Working Plan indicates the Commission’s priorities for developing future product requirements. It does not automatically establish immediate Digital Product Passport obligations for every business operating in these sectors.
For companies in fashion, furniture, manufacturing, mobility and materials, however, the direction of travel is unmistakable. These industries should begin reviewing their product information, supplier data and digital infrastructure before detailed obligations enter into application.
Batteries: the first confirmed passport deadline
For batteries, the obligation is already clearly established under separate European legislation.
Under the EU Batteries Regulation — Regulation (EU) 2023/1542, from 18 February 2027, a battery passport will be required for:
each light means of transport battery, known as an LMT battery;
each industrial battery with a capacity greater than 2 kWh;
each electric vehicle battery.
This makes batteries one of the first product categories with a directly confirmed digital passport obligation in the European market.
For manufacturers, importers and companies operating in mobility, energy storage or industrial battery supply chains, preparation is no longer theoretical. Product identifiers, technical information, supply-chain documentation and access structures must be considered before the legal requirement begins to apply.
Why product data is becoming a strategic asset
The Digital Product Passport is often presented primarily as a sustainability or compliance measure. In reality, it is also a data governance challenge.
Many companies already possess parts of the information that may be required for future product passports. The problem is that these data are often fragmented:
technical specifications are stored in an ERP system;
supplier declarations are kept in files or emails;
certifications are managed separately;
production or batch data sit in manufacturing systems;
repair, resale or recycling information may not be collected consistently at all.
A Digital Product Passport requires companies to move from scattered documentation to structured product information that can be retrieved, updated and shared with the appropriate actors.
This is particularly important for companies with international supply chains. Products manufactured outside the European Union but placed on the EU market may still be subject to applicable European product requirements. The quality of supplier information therefore becomes directly relevant to market access and regulatory readiness.
Trust cannot be added at the end
Making product information visible is only one part of the challenge. The information must also be trustworthy.
A company may claim that a product contains certain materials, originates from a specific production process or satisfies particular sustainability criteria. But customers, partners and authorities increasingly need more than claims: they need information that can be traced, verified and protected against unnoticed alteration.
Digital trust technologies can support this objective.
Blockchain-based verification, for example, does not replace compliance obligations, supplier audits or accurate source data. It cannot turn incorrect information into correct information. What it can do is support proof of integrity and timestamping: demonstrating that a particular digital record existed in a specific form at a particular moment and has not been silently changed.
For Digital Product Passports, this can strengthen the reliability of key records, including certificates, product documentation, origin information and lifecycle updates.
Why waiting for the final obligation can be costly
Some companies may decide to postpone any DPP work until their product category is subject to a final legal requirement. That may appear cautious, but operationally it can create significant risk.
Preparing a Digital Product Passport may require a business to:
identify which products are affected;
locate and consolidate technical information;
request structured data from suppliers;
define product identifiers;
integrate existing business systems;
distinguish public information from restricted information;
test how information is updated across the product lifecycle.
These tasks can take time, particularly for businesses with large catalogues, multiple suppliers, complex manufacturing processes or international operations.
A focused pilot project allows companies to identify gaps early. It can reveal missing supplier information, inconsistent product identifiers, integration limitations or documentation processes that need to be improved before regulatory deadlines become urgent.
Five practical actions companies can take today
Companies do not need to make unsupported claims about compliance in order to start preparing responsibly. They can begin with concrete steps that remain valuable as future requirements develop.
1. Identify relevant product lines
Businesses should identify whether their products fall within sectors already prioritised under the ESPR Working Plan or within legislation that already includes specific passport obligations, such as batteries.
2. Map existing product information
Companies should determine where relevant information is currently stored: internal systems, technical sheets, supplier documentation, certificates, quality records, sustainability files or spreadsheets.
3. Assess supplier data readiness
A product passport may depend on information provided by suppliers. Businesses should evaluate whether those partners can provide reliable, structured and consistently updated data.
4. Determine the appropriate identification level
Future passport requirements may operate at product model, batch or individual item level. Understanding the likely operational implications early helps companies plan architecture, costs and traceability processes.
5. Test a pilot Digital Product Passport
A pilot project on one product line can help a company evaluate data collection, QR or NFC access, system integration, user access rules and methods for protecting the integrity of product information.
From compliance preparation to competitive value
The Digital Product Passport should not be viewed only as a future compliance burden.
For companies that prepare properly, it can also become an instrument of market differentiation.
A credible digital passport can help a brand communicate provenance, strengthen authenticity claims, improve after-sales and repair services, support circularity strategies and give business partners greater confidence in product information.
This is especially relevant in sectors where value depends on quality, origin, sustainability, craftsmanship or traceability: fashion, furniture, luxury, mobility, industrial manufacturing and Made in Italy products.
In these industries, trust is increasingly becoming digital. It must be accessible, structured and demonstrable.
How Notarify supports Digital Product Passport readiness
NotariPassport is Notarify’s white-label Digital Product Passport solution, designed to help companies connect physical products with accessible, manageable and verifiable digital information.
Through QR and NFC access, integration with business systems and blockchain-based integrity verification, NotariPassport supports manufacturers and brands in building the digital infrastructure required for product traceability, data reliability and future DPP readiness.
Notarify does not replace a company’s responsibility to comply with applicable European legislation or future sector-specific requirements. It provides the digital trust infrastructure needed to organise product information, protect its integrity and prepare for a market in which transparency must be supported by evidence.
The Digital Product Passport is not simply a future regulatory obligation. It is part of a broader transformation in how products are documented, verified and trusted across international markets.
Companies that begin preparing their product data today will be better positioned to adapt when sector-specific obligations apply — and better equipped to turn regulatory readiness into a measurable business advantage.
Is your company ready to prepare for the Digital Product Passport?
Book a Digital Product Passport Readiness Assessment with Notarify and identify the data, systems and verification processes required for your next product passport pilot.