On the product, on the box, or in the manual? Where to place the data carrier for the Digital Product Passport

Why Placement Is Not Just a Detail

When discussing the Digital Product Passport (DPP), the focus almost always falls on the data: what information to collect, from which suppliers, and in what format. However, there is a physical point of contact—the data carrier (such as a QR code, Data Matrix, or an RFID/NFC tag)—that acts as the essential link between the physical object and its digital record. Without it, the passport remains invisible.

Deciding where to place this carrier might seem like a mere design choice, but it has concrete implications for:

• Production: Does it require a laser-marking station, an in-line printer, or a supplier for woven labels?
• Packaging: Does the packaging need to be redesigned to accommodate a unique, scannable code?
• Labeling and Logistics: Can the code withstand washing, abrasion, heat, and years of wear and tear?
• User Experience: Will those who need to scan the code—consumers, repair technicians, recyclers, or regulatory authorities—actually be able to find it when the time comes?

What the Regulations Say

Regulation (EU) 2024/1781 (ESPR), which entered into force on July 18, 2024, mandates that the data carrier must be physically present in one of three locations: on the product itself, on its packaging, or on the accompanying documentation. However, it does not establish a single, universal rule; instead, a delegated act specific to each product group (such as textiles, furniture, steel, or electronics) will define exactly where the code must be placed and which technology should be used. While awaiting the delegated acts, the legislator’s rationale is clear: the preferred placement is on the product itself, as this is the only way to ensure the information remains with the item throughout its entire life cycle—even after the packaging has been discarded and the manual lost. Packaging and documentation are considered fallback solutions, to be used only when the nature or dimensions of the product make any other approach unfeasible.

It is also worth noting the definition: under the ESPR (Ecodesign for Sustainable Products Regulation), a "data carrier" is defined as a linear barcode, a two-dimensional symbol, or any other medium for automatic identification that can be read by a device. While the QR code is the most common, it is not the only permitted format.

Comparing the three options

1. On the product (the preferred choice)

The code is printed, engraved, or applied directly onto the item.

Typical examples

• A QR code laser-engraved onto an aluminum profile or a metal component;
• A woven or heat-applied label sewn inside a garment;
• A Data Matrix code marked via micro-percussion on a mechanical part;
• An NFC tag embedded within a shoe sole or a plastic component.

Advantages

• The "passport" remains accessible throughout the product's entire useful life—including during repairs, resale, and at the end-of-life stage;
• It is the solution most aligned with the circularity objectives of the ESPR;
• It facilitates the work of recyclers and regulatory authorities.

Challenges

• It requires adjustments to the production process (new machinery, additional steps, and quality checks to ensure readability);
• It imposes durability requirements: the code must withstand factors such as washing, UV exposure, abrasion, and temperature fluctuations;
• It may conflict with the product's aesthetic, particularly in the luxury and design sectors. ### 2. On the packaging

The code is placed on the packaging when it is not possible or practical to apply it directly to the item itself.

Typical examples

• A QR code on the box of a small household appliance;
• A code on the packaging of very small products or items with surfaces that cannot be marked.

Advantages

• Minimal impact on the production line: the process only involves printing on the packaging;
• More graphic space and flat surfaces, resulting in better readability.

Challenges

• Packaging is usually discarded immediately after purchase; the link to the "passport" may be lost precisely when it is most needed (e.g., for repairs or recycling);
• If the passport is linked to a specific batch or individual item, the packaging must correspond exactly to its contents, creating a risk of misalignment in the warehouse.

3. On accompanying documentation

The code is included in the documents that accompany the product.

Typical examples

• A QR code on a delivery note (packing slip);
• A code in the user manual or technical data sheet;
• A reference included in the documentation for B2B products or bulk materials.

Advantages

• A viable solution for semi-finished goods, raw materials, and industrial products where marking the item itself is impossible;
• No impact on the product or its packaging.

Challenges

• This is the least robust option: documents can easily become separated from the item;
• It is generally unsuitable for products intended for end consumers.

What if you don't know yet?

This is a common situation, especially for product groups for which the relevant delegated act has not yet been published. In this case, it is advisable not to halt the project: one can map out the technically feasible options for each product line and defer the final decision, bearing in mind that a product-based solution is the most "future-proof" approach.

The Case of Batteries: A Preview of What’s to Come

The battery sector is the first area where regulations have already been defined in detail. Article 13 of Regulation (EU) 2023/1542 stipulates that, as of February 18, 2027, all batteries must feature a QR code providing access to the required information.

The code must be printed or engraved onto the battery in a way that is visible, legible, and indelible. Only when the nature or dimensions of the battery make this unfeasible or unjustified may the markings and the QR code be placed on the packaging or accompanying documentation instead.

From the same date, batteries for electric vehicles, light means of transport (such as e-bikes and e-scooters), and industrial batteries with a capacity exceeding 2 kWh must have an individual battery passport, accessible via a QR code (Article 77).

For manufacturers in other sectors, the battery regulation serves as a useful model: the established hierarchy prioritizes the product itself, with other locations serving only as alternatives. Furthermore, the durability of the code is an explicit requirement, not an optional feature.

Practical Criteria for Decision-Making

To determine the appropriate placement, consider the following questions for each product category:

Criterion	Question to Consider	Guidance
Available Surface Area	Is there space on the product for a legible code?	If yes, prioritize the product itself
Usage Environment	Is the product exposed to washing, heat, abrasion, or outdoor conditions?	Opt for durable technologies (e.g., laser engraving, woven labels, RFID tags)
Lifecycle	Who will need to read the code years later (e.g., repair technicians, recyclers)?	The code must remain on the item itself
Production impact	What investments are required for in-line marking?	Assess the costs and timeframes for implementation.
Aesthetics	Is the code compatible with the product design?	Consider discreet yet accessible locations, or invisible tags (NFC/RFID).
Delegated act	Is there already a specific regulation for your product group?	If so, it is binding.

Operational Checklist

1. Inventory your products and group them by ESPR category and physical characteristics.
2. Check the status of delegated acts for each product group and monitor publications from the Commission.
3. Involve production, packaging, and quality teams from the outset: the data carrier is an industrial matter, not just an IT issue.
4. Test the readability of the code under real-world usage conditions and after potential wear or aging.
5. Define the identifier and URL schema (e.g., GS1 Digital Link) before printing or engraving any codes.
6. Develop a contingency plan for products where direct marking is not feasible, and document the reasons why.
7. Align your suppliers—including those for labels, packaging, and components—with the technical specifications for the code.

Conclusions

The placement of the data carrier serves as the link between the physical and digital realms of the Digital Product Passport (DPP). While the ESPR allows for three different approaches, it clearly favors marking directly on the product—the only method that ensures information continuity throughout the entire product life cycle. Companies that approach this decision today—focusing on industrial feasibility rather than just graphic design—will avoid costly redesigns once the delegated acts make the requirements operational.