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EU compliance

Ecodesign and the digital product passport: what happens to your spec sheet

The spec sheet you send to a European buyer is becoming a regulated record, with a defined content and an identifier printed on the product. Publishing it means knowing what is inside, and that is a question for your suppliers before it is a question for your documentation team.

China → France

The spec sheet you send to a European buyer used to be a commercial document. You chose what went in it, and you chose what stayed out. That is ending. Europe is turning part of that sheet into a regulated record with a defined content, published where it can be reached, and carrying an identifier printed on the product so that whoever holds the product can read the record without asking you. The commercial document survives; a second document is settling underneath it, and its content no longer belongs to you.

What ecodesign covers now, beyond the energy label

Ecodesign began as an energy subject, aimed at products that consume electricity, and most exporters still read the word that way. The framework has been widened to product families that have nothing to do with electricity, and the requirements attached to them have stopped being about consumption. They concern how long the product lasts, whether it can be repaired, what share of recycled material it contains, whether substances of concern are present in it, and what can be done with it at the end. The subject has moved from the plug to the material, which is why a furniture maker or a textile manufacturer who assumed this was someone else's problem is now inside it.

What a digital product passport actually is

It is not a brochure in digital form, and it is not the page you already publish about the product. It is an identifier carried by the product itself, by its packaging or by its documentation, which resolves to a structured record. The record is read by different people for different reasons — an authority checking compliance, a customs officer, a repairer looking for a part, a recycler deciding how to separate the materials, a customer asking what the thing is made of — and each of them sees the layer intended for them. Two properties make it harder than it sounds: the identifier has to be unique at the level the rules require, which may be the model, the batch or the individual item, and the record has to stay reachable for the life of the product, which is longer than the life of most company websites.

  • What the product is made of. The materials, named rather than described commercially, and the presence of substances of concern where the rules require it to be disclosed. This is the line that decides whether the rest of the record is achievable.
  • How long it is expected to last, and how that was established. Durability expressed in the terms the family's own text defines, with the test or the method behind it rather than a marketing claim.
  • The parts, and how to get them. Which references are available as spare parts, to whom, and through which channel. A record that lists parts nobody can actually order is read as a refusal.
  • How it is repaired and dismantled. The documentation a repairer needs, the order of disassembly, and the tools it requires. The same information serves the repairer and the recycler, for opposite purposes.
  • What happens at the end of life. Which materials go where, what has to be removed before treatment, and which collection channel applies. This is the part the recycler reads, and the part most records are thinnest on.
  • Who answers for it. The manufacturer, and the party established in the Union that holds the file and can be contacted. A record without a reachable name behind it is a record an authority treats as absent.

Why this is a sourcing problem before it is a documentation problem

To publish what is inside the product, you have to know it, and that is where most manufacturers stop. A factory that moulds its own parts from resin it buys by the sack knows what it buys. A factory that assembles purchased sub-assemblies — a motor, a board, a cable, a fabric already dyed and coated — does not, because its own bill of materials records a commercial description and a price, not a composition. Ask the supplier and you often find that the supplier does not know either, for exactly the same reason: it bought the material further up. The information exists somewhere in that chain. It has simply never been asked to travel downward, and building the path takes months of patient asking that cannot be compressed into the week a customer finally asks.

Which product families are covered, and is mine next?

The requirements do not arrive all at once. A framework sets the machinery, and then each product family receives its own implementing text, with its own list of requirements, its own data to publish and its own calendar. The catalogue of covered families is therefore a moving list, extended by working plans that are revised. Which makes the question every exporter asks — when does this hit us — a question whose answer expires. The question that does not expire is a capability question: if a European buyer asked today for the composition of this product, the repair documentation and a stable reference per saleable item, could we produce it, and how long would it take us? A company that can answer that is ready whatever the calendar says, and a company that cannot will be late whatever warning it was given.

What a manufacturer can build before the requirement arrives

  • A clean bill of materials, held as data. A complete list per saleable reference, down to the purchased sub-assembly, with the supplier named against each line and a version that changes when the part changes. A bill of materials that lives as a note on a drawing cannot feed anything.
  • Declarations from your own suppliers. A written statement, per part reference, of what the part contains and what it complies with, signed by someone the supplier can be held to. Obtained once as a favour it is worthless; obtained as a standing condition of the purchase order it becomes a system.
  • A stable reference per product. An identification that does not change when the catalogue is renamed, the packaging is redesigned or the sales team invents a new commercial label. Every record you will have to publish hangs off that reference, and renaming it later means rebuilding everything attached to it.
  • A place where the record will live. Not the marketing site, which gets rebuilt, but an address you control and intend to keep, with whoever maintains it knowing that the obligation outlives the product on the shelf.
  • A named person who owns it. Someone in the company whose job includes keeping the material data current, rather than a task that moves between engineering, quality and export depending on who received the email.

Start with the product you sell most of in Europe, and write its bill of materials down to the purchased sub-assembly, with a supplier name on every line. Then send the same short declaration request to each of those suppliers and see who answers. The ones who answer are the chain you can document; the silence tells you exactly where your product passport will fail, and it tells you now, while the only cost of knowing is a difficult conversation rather than a lost listing.

Where to read it yourself

Official pages, opened and checked on 15 October 2026. Where a rule changes, these are the addresses that change with it — this article does not.

Questions we get on this.

Do we need a product passport if we sell only through a European distributor?

The obligation attaches to the product being placed on the market, not to who signs the invoice, so selling through a distributor does not make it disappear — it only moves the question of who assembles the record. In practice the distributor or importer will ask you for the data, because it is the party exposed if the record is missing, and it cannot invent a composition it does not know. The useful way to read this is commercial rather than legal: a distributor that cannot get the data from you will eventually prefer a supplier that provides it, and that decision happens quietly, at the next range review, without anyone telling you that was the reason.

Is a code printed on the packaging enough to count as a passport?

The code is the doorway, not the passport. What matters is what it leads to: a structured record with the content the product family's text requires, readable by machines as well as by people, kept available for the life of the product, and carrying the layers that different readers are entitled to see. A code that opens a product page written for buyers fails on every one of those points, even though it looks identical from the outside. Where the code is placed also matters, because packaging is discarded while the product is repaired and recycled long afterwards, which is why some families require the carrier to be on the product itself.

Our supplier refuses to disclose the composition of a component. What do we do?

Separate the refusals, because they are not the same problem. A supplier protecting a formulation can usually still declare what you actually need — the presence or absence of the substances the European lists cover, and the material families — without revealing proportions; offer that narrower question before concluding anything. A supplier who cannot answer even that does not know, and the honest ones will say so, which turns the task into going up to its own supplier with it. The refusal that should worry you is the one with no explanation, because it usually means the part is not what the datasheet says. In every case, make the declaration a condition of the next purchase order rather than a request, and qualify a second source for the parts where the answer never came.