Under the EU Ecodesign for Sustainable Products Regulation, many goods sold in the Union will need a Digital Product Passport: structured data about materials, repair, substances, and (for batteries) chemistry and lifetime — reachable from a data carrier on the product. In practice that carrier is a QR, usually a GS1 Digital Link.
The QR does not hold the passport. It points at a hosted page with tiered access (public vs authorities vs supply chain). If you treat the QR as a PDF dump, you will reprint the pack every time the dossier changes.
Who and when (do not round to “2027 for everyone”)
- Batteries (EV, industrial, light-transport above the capacity threshold): obligations from 18 February 2027.
- Textiles and apparel: delegated acts later; realistic operator planning is 2028–2029, not “this Christmas”.
- Electronics, furniture, tyres, steel, chemicals: later waves. Watch the official ESPR calendar; do not print a “DPP compliant” flash for a category that is not in force.
This article is an implementation sketch, not legal advice. Your notified body / counsel owns the dossier fields.
What the QR must do
- Survive the life of the product (years, not a campaign).
- Resolve to a passport URL you can update without a new die.
- Prefer a GTIN-based Digital Link so POS (Sunrise) and DPP are one symbol where the category allows it.
- Support machines (
linkset) as well as humans. A pretty landing page is not enough if a customs system asks for link types.
Walkthrough of a GTIN QR (static test). Production passports belong in a workspace so lot/serial and routing can change:
What to put on the page
Typical public fields: manufacturer, origin, materials and recycled content, hazardous substances, repair/disassembly, carbon if you have a method, certifications. Batteries add chemistry, capacity, expected lifetime, and hooks for state of health as the acts specify.
Do not invent percentages. Publish what you can evidence. Country routing (a German repair URL vs a French one) is a smart redirect, not a second QR.
3PL and co-packer notes
The passport is the brand’s. The 3PL’s job is usually: apply the agreed label, not author REACH. Prefer one generic pack QR if the passport is GTIN-level; per-lot QRs only when the dossier or traceability requires it (sticker variants).
If the 3PL also stores the “scan for IFU” consumer URL, do not add a third code. Same Digital Link, different linkType or a landing with two buttons.
Hosting
Passport pages need to outlive the agency that built the microsite. Domain on your account, never-dies redirects, escrow export. Product path: Digital Product Passport and App → GS1 / Passports.