The Digital Product Passport (DPP) is a structured record of a product's identity, materials, compliance and circularity data, and the Ecodesign for Sustainable Products Regulation (EU) 2024/1781 requires a data carrier on the product, its packaging or its documents so people can reach it. A QR code is the obvious carrier, but the ESPR doesn't name it. The one place the law names a QR code is the battery passport.
Source note: EUR-Lex returned an empty page to automated fetches on 2026-10-25, so I couldn't re-read the article text that day. The regulation and its dates below are the ones I'm confident of, linked to the official journal for you to check, and I state no date I couldn't confirm. This isn't legal advice for your product.
What the ESPR Says About the Carrier
Two things sit behind the phrase, and the regulation treats them separately.
- The passport: the data record, held to a product-specific data model.
- The data carrier: defined in the ESPR as a linear barcode, a two-dimensional symbol or another automatic data capture medium that a device can read. It links to the passport through a unique product identifier.
The regulation entered into force on 18 July 2024 (accessed 2026-10-25, EUR-Lex). It's a framework: the actual passport content and carrier format for each product group come from delegated acts, which is why a blanket "QR code required from 2027" claim, common in vendor posts, is wrong.
The Dates You Can Plan Around
Only one date is hard today.
- Batteries, 18 February 2027. The Batteries Regulation (EU) 2023/1542 requires a battery passport, reachable via a QR code on the battery, for electric vehicle batteries, industrial batteries over 2 kWh and light means of transport batteries placed on the EU market (accessed 2026-10-25).
- Everything else is unconfirmed. Textiles, tyres, steel, furniture and other groups depend on delegated acts and a compliance window after each one is published. I couldn't load an official page confirming a published act or date on 2026-10-25, so I won't quote one. Check the European Commission's ecodesign pages for your group.
If you make batteries, the clock is short. For anything else, the useful move is deciding the carrier setup now, because that part won't change with the delegated acts.
What Sits at the End of the Redirect
The scan should land on something a regulator, a recycler and a customer can all use. Keep the page light and readable on a phone, put the product identity at the top, and make each data block reachable without a login unless the product rules restrict it. Anyone scanning a worn label will land here first, so a slow or broken page counts against you immediately.
On the redirect itself, Elido sends a 302 by default and lets you set 301 or 307 per link. For a printed carrier that you may repoint, the default temporary redirect is the safer choice, because browsers and apps won't cache the old destination for long. Switch to a permanent redirect only when the passport address will never move.
Why the Carrier Is a Durability Decision
A product with a DPP can live ten years or more, and the passport has to stay reachable through resale, repair and recycling. That turns three ordinary QR choices into compliance choices.
Indirection. A static code bakes the destination into the pattern. If the passport host changes, every unit already shipped points at a dead page. A dynamic QR code encodes a short redirect you control, so you can repoint it without reprinting.
Resolution. A code that returns a 404 under a market surveillance check is a non-conformant carrier. Whatever runs the redirect needs to be dependable for years.
Location. The record touches product data and sometimes personal data, and it's an EU-market obligation. Hosting the resolver in the EU avoids adding a transfer analysis on top, the same logic as in GDPR for URL shorteners. Elido's data is primary in the EU, but edge servers on three continents also handle visitor requests, so describe it as EU-primary rather than EU-only.
GS1 Digital Link: What Elido Does and Doesn't Do
Many manufacturers already carry GS1 identifiers, and GS1 Digital Link is a URL syntax that puts a GTIN, lot or serial number in the path of an ordinary web address. It's a natural fit for a passport carrier, so the dashboard has a GS1 Digital Link tab next to the standard QR designer.
What the code does, checked in services/api-core/internal/qr:
- It builds
https://<host>/01/<gtin>and appends lot, expiry and serial segments, and it validates the GTIN check digit for 8, 12, 13 and 14 digit codes. - It renders PNG or SVG, with error correction L, M, Q or H (Q by default).
- The builder is a Business plan feature in the dashboard.
What it doesn't do, and where I'd stop short of calling it a DPP resolver:
- The edge doesn't resolve
/01/...paths. The builder generates the URL, but nothing maps a GTIN path to a passport page yet. You'd have to host that mapping yourself. - The quiet zone is the standard 4 modules. Don't crop it or place the code flush against busy artwork.
- Expiry goes in the path. GS1's syntax treats data like expiry as query parameters in the usual form; I couldn't load gs1.org on 2026-10-25 to check, so test the output in a GS1 conformance resolver before you print.
So for a passport today, the accurate use is a short link that redirects to your passport page, with the code carrying your own domain. The GS1 builder is a convenience for the identifier format, not a registry or a resolver. Elido doesn't store passport data at all. Set up a dynamic QR code for the redirect layer and build or buy the passport itself separately.
What to Do Before Your Deadline
- Confirm whether your product group is in scope, and find its delegated act on the Commission's ecodesign pages.
- Decide the carrier as a durability question: a redirect you own, not a hard-coded passport URL.
- Pin down where the resolver and the record live, and prefer EU hosting for an EU-market obligation.
- Test the printed code on the real surface, at the real size, using the size rules.
- Treat the passport data model as its own project.
Read the Cornerstone Series
This sits in the compliance cluster. For QR mechanics start at how to create a QR code, and for the data-location argument the GDPR cornerstone linked above.
Related on the Blog
Frequently asked questions
What is a Digital Product Passport QR code?
It's the data carrier printed on a product or its packaging that leads to the product's Digital Product Passport, a structured record of identity, materials, compliance and circularity data. The ESPR defines a data carrier as a machine-readable symbol such as a linear barcode or a two-dimensional code, so a QR code qualifies but isn't named as the only option.
When is the Digital Product Passport required?
Product group by product group. The one firm date is for batteries: under Regulation (EU) 2023/1542 the battery passport applies from 18 February 2027 to electric vehicle batteries, industrial batteries over 2 kWh and light means of transport batteries. For textiles, tyres, steel and others the dates depend on delegated acts, and I couldn't confirm a published date on 2026-10-25, so this guide states none.
Does the ESPR require a QR code specifically?
No. It requires a data carrier linked to a unique product identifier, and leaves the format to the product-specific rules. For batteries the Batteries Regulation does name a QR code. For other groups, QR is the likely choice because every phone reads it, but check your group's delegated act before you print anything.
What happens if my product has no Digital Product Passport?
For a product group that's in scope and past its application date, the passport is a condition for placing the product on the EU market, so a missing or non-conformant one can block sale and invite enforcement by market surveillance authorities. Penalties are set by each member state, so the exact consequence depends on where you sell.
Can Elido host a Digital Product Passport?
No. Elido provides the link and the QR code that resolve to wherever you host the passport, and it can generate a GS1 Digital Link style URL from a GTIN. It doesn't store passport data, and the edge doesn't yet resolve GS1 paths on its own, so you point the link at your own passport page.
Where should the Digital Product Passport data be hosted?
The passport has to stay reachable for the product's lifetime, so pick a host you'll still control in ten years. The ESPR also provides for independent third-party passport providers and a central registry. Keep the QR pointing at a redirect you own, so the hosting can change without touching printed packaging.
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