Product passport Q & A


The EU is expected to implement a new law on product passports within a couple of years. This law will require that almost all products put on the European market have a product passport that will provide reliable sustainability data down to the smallest component – all to increase traceability and facilitate a circular economy. Within the ProPare project, we are working to develop the underlying infrastructure for digital product passports. Here are answers to some of the most frequently asked questions about the upcoming product passport legislation.


Question: What does the ProParare project do?

Answer: ProPare develops the infrastructure that underlies digital product passports. The ProPare project aims to develop the underlying digital product passport infrastructure. The solution is based on an open, competition-neutral, and global standard, and the ambition in the long run is that it will be useable for linking all types of data to products, regardless of industry, company or product category. The ProPare project is conducted in a broad collaboration between Axfoundation, Swedish Trade Federation, Ecolabelling Sweden AB, GS1 Sweden who is part of the global standards organization GS1 as well as trading companies, brand owners, producers, third-party certifiers and technology developers. There are three brands in the pilot phase (Feb 2022-Mar 2023): Ahlsell, Dagab and Mio. App developer is Blue Cromos.

Question: What does ‘global and competition-neutral standard’ mean?

Answer:  A standard that anyone may use and which is designed to function in all parts of the world and where parties in all countries can participate in governance of the standard.

Question: What is a Resolver Function?

Answer: An IT system that enables verified product data to be transferred from a number of different sources to a number of different recipients in real time, without any distortion along the way.

Question: What do you mean by demo app?

Answer:  A mobile application designed to create an understanding of how the underlying product passport infrastructure works and how it can be scaled up to comprise more information elements and more products.

Question: Why is Nordic Ecolabel certification included as product information in ProPare?

Answer: Certification means that a certification organization has established requirements for environmental performance, and verified that the product meets the requirements. The certifying body is a representative of the consumers and buyers who want such requirements to be set. In ProPare, information about whether the requirements are met is retrieved directly from Nordic Ecolabel, which is responsible for the Nordic Swan ecolabel.

Question: What requirements does a product that has been certified with the Nordic Ecolabel meet?

Answer: A product that has been awarded the Nordic Ecolabel meets environmental, health and quality requirements, specific to the product, at all relevant stages of the lifecycle – raw materials, production, use, reuse, and recycling. The requirements are designed to protect the environment and health by focusing on biological diversity in forests, on land and in the ocean, the restriction of hazardous substances, resource efficiency, circular economy, and the reduction of greenhouse gas emissions.

Question: What is a Product Passport?

Answer: A Product Passport is a set of product-specific digital data for the purpose of making relevant information visible during the product lifecycle, in order to contribute to more Sustainable Production & Consumption. The Product Passport aims to increase traceability and facilitate a circular economy through the sharing of different sustainability data by manufacturers for their products. For example, the information may relate to characteristics, content, ecolabels, origin, use, recycling, etc.

Question: When will there be a regulation on Product Passports?

Answer: The legislative framework of the EU for Product Passports (Ecodesign for Sustainable Products, ESPR) is expected to be decided during the spring of 2024. The EU will then subsequently publish more detailed product rules for the product-specific categories. The forecast is for 3-4 categories per year, and a total of approximately 30 categories.

Question: Will the law apply to all products?

Answer: The regulation is expected to apply to all products that are sold on the EU market, excluding foodstuffs, animal feed, and medical products.

Question: Which products will be the first to get product-specific legislationregulation?

Answer: It is expected that first product-specific legislation introduced by the European Commission will be for textiles, electrical products, batteries, and furniture.

Question: Will the law apply only in the EU, or also outside the EU, i.e., for products produced outside the EU?

Answer: The legislation will apply to all products sold in the EU, irrespective of where they are produced. It is the importing party that is bringing the product into the EU, that is responsible for ensuring that there is a Product Passport available.

Question: What applies to food packaging?

Answer: The EU says that it is not currently planning for special Product Passports for packaging within the framework for Ecodesign for Sustainable Products, ESPR, but this could change.

Question: We sell foodstuffs – teas in boxes and bags that are recycles – what more can we do?

Answer: According to current information from the EU (November 2022), there is no product-specific legislation planned for Ecodesign for Sustainable Products, ESPR. However, for foodstuffs and packaging there is other special relatable legislation, which in some cases may require information equivalent to that of ESPR.

Question: When might there be product-specific legislation for other products, such as paints and beeswax, chemicals, detergents, and other chemicals?

Answer: The EU has not communicated a timeframe for the different product categories that will be regulated within the framework forEcodesign for Sustainable Products, ESPR. For some products, such as building products, which may include paint, there are currently other regulations with corresponding requirements for the reporting of certain sustainability information.

Question: Could digital Product Passports be implemented in health care as a solution, so that all countries can have up-to-date product information about medical devices, instead of all countries/regions managing commodity data either via their own databases, product catalogs Global Data Synchronization Network (GDSN)?

Answer: Technically, the answer is yes, but in such a highly regulated market as medical devices, changes do not always happen so quickly. Medical devices are excluded from the current legislation regulation for Product Passports, (Ecodesign for Sustainable Products, ESPR).

Question: Are there existing projects that are developing Product Passports for the textile industry right now?

Answer: Yes, for example, in Sweden there is the TrusTrace project (sub-project within Trace4Value), and the Productpass project as an enabler for the circular flow of furniture, both of which include textile products. The EU-funded project, CIRPASS, develops prototypes for Product Passports in three categories, of which textiles is one.

Question: Will Product Passports be able to identify at the product category level, or at the level of individual specimens of the product?

Answer: It will depend on the product category. In many cases, products that require management throughout their lifetime need to be identified at the individual level, while for consumables, product level or batch level will suffice.

Question: Will Product Passports contribute to the development of products so that they can be more easily repaired, for example, when replacing broken parts? Will manufacturers who produce repairable products then sell fewer products? For example, today, if a consumer has a cell phone in which a part breaks, and the part cannot be replaced – then of course the consumer is “forced” to buy a new cell phone.

Answer: One of the purposes of Ecodesign for Sustainable Products, ESPR, which includes the Product Passports, is to steer towards business models that are more circular and resource-efficient, so if ESPR has the intended effect, the answer to the question is probably “yes”. Therefore, it becomes important for companies to develop their offer with services, servicing, spare parts, etc.

Question: How will it work with GDPR and secured personal privacy, if you are going to keep a log of previous owners to ensure that the product is not stolen?

Answer: Of course, there may be ways available in which to ensure that the product is not stolen, other by knowing who the previous owners were. For example, it might be sufficient for the product to not be listed in a stolen property register.

Question: Do the Product Passports contain any rules/standards with regard to the definitions of characteristics? For example, how can characteristics be unambiguously identified/communicated without making automation more difficult?

Answer: Part of the ongoing work in the lead up to the issuing of product-specific legislation, will be to select existing terminologies/taxonomies, or define and standardize terminologies/taxonomies for the characteristics that need to be reported in the Product Passports.

Question: Will the Product Passport (QR code) need to be present on the product or on the packaging?

Answer: The product identity (for example, encoded in a QR code) should be present on the product, or be included in the documentation that accompanies the product. Normally, the same code will probably also be present on the packaging, in order to facilitate the purchase decision (so that consumers can access the information prior to purchase), and to be able to use the code at the store checkout when purchasing, without having to open the packaging.

Question: What is the decision-making process in the EU regarding Product Passports?

Answer: On 30 March 2022, the European Commission presented the Bill, Ecodesign for Sustainable Products, ESPR, which requires the development of a digital product passport. The EU Council and the European Parliament are preparing their respective positions on the Bill, and the three parties will then negotiate the final legislation via a so-called “trialog”. At the earliest, the negotiations (the trialog) should be completed by early 2024. Following that, the Product Passport should be implemented in product-specific legislation, which at the earliest, should happen in 2025. However, the timeframes may very well change over the course of the negotiations.

Question: I think it is relatively good to find information about what should be in the product passports regarding the manufacturing process, but have difficulty finding information about what should / must be included about how the specimen is used (for example, how it is repaired, washed, etc.) Where is the info available about that? Are there frameworks developed for it?

Answer: There is not a lot of information about it, nor is there a clear or uniform picture of how it should be done. This is not even very clear in the Ecodesign for Sustainable Products Regulation, ESPR, while there are frequent mentions of it in the EU communication on ESPR. This will be one of the many questions that will need to be answered when the roll out of the product-specific legislation starts.


Question: How is the work coming along on getting a standard for measuring the CO2e and environmental footprint of products? Preferably, specifically for IT products (PCFs on laptops, computers, etc.).

Answer: With regard to measuring the “Product Carbon Footprint”, there is already a plethora of standards, environmental declarations or tools that do this to different extents (e.g., ISO 14040, ISO 14044, ISO 14067, ISO 14025, PAS 2050, Product attribute to impact algorithm tool (PAIA) etc.). But the manufacturers don’t always do the same, partly due to the fact that some of the standards are very broad, but also because manufacturers have some flexibility in how they choose to evaluate their products. TCO Development monitors the methodology that is behind the EU, PEF (Product Environmental Footprint), where so-called Category Rules can be developed for a certain type of product in order for them to be comparable. In terms of IT products, such as laptops and computers, there has not yet been a lot of progress on getting Category Rules for this, and it is at least another couple of years away. As there is such wide variation in the underlying basis, TCO Development believes that at present, PEF should not be used as a basis for decision-making when purchasing a product. However, it is possible to use PEF to get some idea of the effects of the products that you buy.


Question: When will SIS, the Swedish Institute for Standards, be finished with the standardization around circular economy?

Answer: Standardization work usually takes some time, as there may be more related issues that arise that need to be addressed. The first standards on terminology, guidelines, etc., will be published for public consultation in 2023, and are planned for publishing in late 2023 or early 2024, but of course, all of this is dependent on the volume of comments and the outcome of the votes. The SIS website shows work in progress under the “Now working with” tab.

Question: How can different actors access the Product Passport at a later stage, when the packaging is no longer available? Surely the 2D code is placed only on the packaging?

Answer: According to the Ecodesign for Sustainable Products Regulation, ESPR, the idea is that data carriers with identifiers should be placed directly onto the product, using a technology that will make it stay in place, and be legible, throughout the life of the product.