Regulation (EU) 2024/1781 · delegated acts per product group
The product passport is a data problem, not a labelling problem.
A QR code is quickly printed. The information behind it – material composition, origin, repairability – comes from a chain most companies do not fully know.
The Ecodesign for Sustainable Products Regulation replaces the old ecodesign directive and extends far beyond energy-related products. Requirements are set per product group in delegated acts, staggered over time.
The supply chain core is the digital product passport: a machine-readable dataset accompanying a product through its life. Contents range from material composition and substances of concern to information for repair and recycling. No manufacturer can produce that alone – it originates at the suppliers.
Where the data must come from
- Material composition broken down to component level.
- Recycled content, evidenced rather than estimated.
- Substances of concern and their position in the product.
- Information on disassembly, spare parts and repairability.
- Origin and production sites of the main inputs.
What companies face
- Product groups
- Track when your product group comes up – the acts arrive in stages.
- Data model
- Define which information must be collected per component.
- Supplier duties
- Anchor data delivery contractually, updates on change included.
- Data quality
- Carry the provenance of every figure: measured, calculated or estimated.
- Currency
- The passport travels with the product – stale data stays visible.
How SCRM covers it
Supplier per component
The link between component and source, without which no passport can be filled.
Data requests with deadlines
Request information in structure instead of collecting mail attachments.
Provenance of the figure
Measured, calculated or estimated – the difference decides under scrutiny.
Track changes
A material change at a supplier becomes an event, not a surprise.
Frequently asked
From when must we deliver?
It depends on the product group. Requirements arrive in delegated acts published gradually. Knowing early which data is missing is the advantage.
Does this affect Swiss manufacturers?
Once products are made available on the EU market, yes – market access decides, not the registered seat.
Can we estimate figures?
Partly, but the method must be disclosed. Primary data from the chain is more robust and increasingly expected.
As of July 2026. Requirements per product group are partly still pending. Not legal advice.