This is released under the framework of the EU Green Deal setting the objective of becoming the first climate-neutral region by 2050. 

The draft regulation includes the EU digital product passport, a new concept on which GS1 in Europe has been proactively engaging during the last two years. Only a few sectors, such as food, feed, and medicinal products, are exempted and it applies to any physical good, including components and intermediates products, placed on the EU market or put into service. This definition includes products manufactured in Europe or exported into the EU. In this sense, the regulation impacts global trade.

In addition, the regulation prohibits the destruction of unsold consumer products, and it sets mandatory green public procurement criteria.

The overall aim of the proposal is to reduce the life cycle environmental impacts of products through efficient digital solutions but also to enable the objectives of EU industrial policy like boosting the demand for sustainable goods and supporting sustainable production.

The regulation sets up new duties and rights for: manufacturers, importers and distributors, dealers, repairers, remanufacturers, recyclers, maintenance professionals, customers, end-users, consumers, national authorities, public interest organisations, the EU Commission, or any organisation acting on their behalf.

The Commission has also adopted the Sustainable and Circular Textile Strategy and the revision of the Construction Products Regulation. 


On the EU digital product passport

The fact that products should carry a passport is not new, and definitely not new in GS1. The real change is that this is happening through legislation and by leveraging both green and digital transformations.

The regulation states that “the product passport means a set of data specific to a product that includes the information (specified in the delegated act) and that is accessible via electronic means through a data carrier”. 

Under the new regulation, the product passport shall: 

- ensure that actors along the value chain, including consumers, economic operators, and competent national authorities, can access product information relevant to them

- improve traceability of products along the value chain

- facilitate the verification of product compliance by competent national authorities

- include the necessary data attributes to enable the tracking of all substances of concern throughout the lifecycle of the products covered

For GS1, it is important to note that product passports shall be fully interoperable with other product passports across all product groups, including in relation to the technical, semantic and organisational aspects of inter-operability, end-to-end communication, and data transfer. So, the product passport becomes an enabler of interoperability but also a necessary element to place products on the EU market under the conformity assessment procedure.

In addition, the regulation clarifies that consumers, economic operators and other relevant actors shall have free access to the product passport based on their respective access rights.


Open, global standards referenced by the draft regulation

It is very important to note that the draft regulation references global and open standards several times. This reflects what an important role we can play to meet both industry and regulators' demands. 

This is a call to action for at GS1! 

Here follow non-exhaustive examples: 

• In order to ensure interoperability, the data carrier and the unique product identifier should be released in accordance with internationally recognised standards

• To ensure that the product passport is flexible, agile and market-driven, and evolving in line with business models, markets and innovation, it should be based on a decentralised data system, set up and maintained by economic operators

• Unique identification of products is a fundamental element to enable traceability across the supply chain. Therefore, the product passport should be linked to a unique product identifier. In addition, where appropriate, the passport should allow for the tracing of the actors and manufacturing facilities related to that product. In order to ensure interoperability, the unique operator identifiers and unique facility identifiers enabling traceability should be released in accordance with internationally recognised standards

• ‘Unique product identifier’ means a unique string of characters for the identification of products that also enables a web link to the product passport

• ‘Unique operator identifier’ means a unique string of characters for the identification of actors involved in the value chain of products

• ‘Unique facility identifier’ means a unique string of characters for the identification of locations or buildings involved in the value chain of a product or used by actors involved in the value chain of a product

• The data carrier and the unique product identifier shall be released in accordance with ISO/IEC 15459:2015 

• All information included in the product passport shall be  based on an open standard, developed with an interoperable format and shall be machine-readable, structured, and searchable

• The unique operator identifiers and the unique facility identifiers shall comply with the ISO/IEC standard 15459:2015

• Customs declarants shall include the unique product identifier in the customs declaration for release for free circulation of any product covered


Next steps

The draft regulation starts as of today the co-decision legislative procedure which requires the involvement of the European Parliament and the Council. This process may take up to 16/18 months.

At the same time, the Commission needs to carry out a prioritisation of products to be regulated under the new Regulation and requirements that will apply to them. To do so, the Commission is adopting a working plan, covering at least 3 years, laying down a list of product groups for which it plans to adopt delegated acts. Data requirements to be decided cover:

• the information to be included in the product passport for consumers, economic operators and competent national authorities

• the layout in which the data carrier shall be presented and its positioning

• whether the product passport should correspond to the model, batch, or item level

• the manner in which the product passport shall be made accessible to customers before they are bound by a sales contract, including in case of distance selling

• the actors that may introduce or modify the information in the product passport, including where needed the creation of a new product passport

•  the period for which the product passport shall remain available

• the specific access rights at product group level

It is estimated that the Commission will introduce 18 new delegated acts, between 2024-2027, and 12 new delegated acts, between 2028-2030, to enable the potential of the product passport. 

So GS1 in Europe estimates that the product passport is a workstream that will be active for at least 10 years. Based on the work developed so far, GS1 in Europe has set some basic principles for the data architecture of the product passport according to the GS1 standards. To read the full data architecture paper, download the document below.

To access the full text of the draft regulation, please click here.

For more information please contact Francesca Poggiali (