Regulation 2024/1781 is the framework. The first hard passport date is 18 February 2027, for batteries under Regulation 2023/1542.
A QR code can point at a product. It cannot assemble the data that a passport is supposed to carry.
Regulation (EU) 2024/1781 — the Ecodesign for Sustainable Products Regulation — is the Union framework for performance, information and a Digital Product Passport. It has applied as a framework since 18 July 2024. It does not, by itself, set one passport date for every product. Concrete data fields, carriers and deadlines come per product group, through delegated acts. The first working plan prioritises textiles, furniture, tyres, mattresses, iron and steel, and aluminium.
The first mandatory passport already has a date. Under the Batteries Regulation (EU) 2023/1542, a battery passport applies from 18 February 2027 for the covered categories — electric-vehicle, industrial and light-means-of-transport batteries above the stated capacity. A central registry is an index, not a data store: it points to where the economic operator hosts the passport.
The product record is the operating test
A passport is structured data about a specific item or batch: identity, composition, substances, performance, dismantling, and whatever the delegated act requires — accessible via a data carrier, typically a QR code, and updatable across the life cycle. That information is spread across PLM, ERP, suppliers, tests and after-sales. A sustainability PDF, a catalogue page or a one-off project site will not survive a model change or a spare-part revision.
Later ESPR groups will reuse the same problem: a unique identifier, a hosted dataset, a carrier on the product, registration in the index, and a way to update the record when the product changes. Building that only for batteries, as a brochure, leaves textiles and steel to start again.
The risk is not only missing 18 February for batteries. It is treating the passport as a label when it is a product-data system.
Where readiness breaks
- Master data: which products, batches and identifiers are in scope, and which delegated act or sectoral rule applies.
- Collection: component and supplier data, tests and declarations that can be mapped to a passport schema rather than a shared drive.
- Lifecycle: who generates the passport, who hosts it, who updates it after a change, and how QR or API access still resolves.
These are connected decisions. Treating ecodesign, IT and supplier quality as separate programmes leaves the organisation with a code on the product and an empty record behind it.
What Ontzi builds
Ontzi turns the obligation into a passport operating model. We connect product master data to component and supplier collection, generate a structured passport, put a QR or API in front of it, and keep lifecycle updates in the same system.
The immediate output is a record that can be identified and shown. The durable value is a repeatable capability: the organisation knows what each product is, what sits in it, who owns the data and how the passport stays true after the line moves.
The framework is the rule. The operating model is what makes a passport usable.
Primary text
- Regulation (EU) 2024/1781 — ESPR official text
- Regulation (EU) 2023/1542 — batteries official text
- Commission page on the Ecodesign for Sustainable Products Regulation
This field note is general information, not legal advice. Which product groups are in scope, and on which date, depends on the relevant regulation or delegated act and should be checked for each manufacturer.