You do not need new labels to start with a digital product passport
The most common reason small brands postpone the digital product passport is a number: the cost of reprinting labels, hang tags, boxes and inserts across the whole range. It is a real number and it is usually wrong, because it answers a question the rules do not ask. The requirement is that the passport is reachable from the product. Printing it on the product is one way to satisfy that. It is not the only one.
Five places, not one
EN 18220, the European standard covering data carriers for product passports, recognises five different ways of attaching the carrier to a product. Described in ordinary terms, they are:
- marked on the product itself - engraved, etched, printed directly on the item
- on the packaging - the usual assumption, and the expensive one
- on a label attached to the product or the packaging
- in accompanying documentation, which may be physical or digital
- embedded in the product - the standard mentions textiles and tyres as examples
The fourth one is where the money is. The standard explicitly contemplates digital documentation, and names examples: an e-commerce page, a digital receipt, a customer account, an email.
What that means in practice
If you sell online, you may be able to start with no physical change at all. The passport link lives on the product page and in the order confirmation. Nothing gets reprinted. Nothing gets thrown away.
There is one condition worth reading twice: if documentation is the only place the identifier appears, then the data carrier has to be included in that documentation. In other words, a bare sentence saying "your passport is somewhere on our website" does not do it. The carrier itself - the code, or the link - has to be there.
The second thing brands get wrong
The standard also assumes that implementing a passport does not necessarily mean introducing a new data carrier. Existing codes on your products may already satisfy part of the requirement.
If you are already printing a GS1 code for retail checkout, that code is built on an identifier that can carry a passport too. Whether it does depends on how it is encoded and where it resolves, but the identifier is not the problem. The starting position is much better than most brands assume.
The right first question to a supplier is therefore not "how much to reprint everything" but "what do my existing codes already give me". Any supplier who cannot answer that is selling you work rather than compliance.
A sensible order of operations
- Start digital. Product page and order email. Fastest, cheapest, reversible.
- Add the code at the next print run. Not a special run - the next one you were going to do anyway. Label changes cost almost nothing when they ride along with a reprint you already planned.
- Only then consider the product itself. Marking or embedding is the most durable option and the most expensive. It earns its cost on products that outlive their packaging, which is most durable goods and very few consumables.
The trade-off nobody mentions
Digital documentation is the cheapest entry and the weakest link. Packaging gets thrown away. Emails get deleted. Web pages move. The physical durability of the carrier is exactly what the standard cares about elsewhere: it expects a carrier to survive several cycles of use, resale and repair.
So the honest framing is not "digital instead of printed". It is digital now, printed when you print anyway. You get compliance early and durability later, without a special budget for either.
What to do this week
- Count how many products you sell online with an order confirmation email. That is your zero-cost starting set.
- Find out when your next label or packaging print run is scheduled. That is your deadline for deciding what goes on it.
- Check what identifier your existing codes carry. If you are in GS1 already, you are further along than you think.
None of this requires choosing a platform first. It requires knowing your own print calendar, which you already do.
FAQ
Is a digital receipt really enough?
As a carrier location, the standard treats documentation as a legitimate option and explicitly includes digital forms. Whether it is enough for your product depends on the delegated act for your product group, which can require a specific carrier.
Do I need a QR code at all?
You need the passport to be reachable and machine readable. A QR code is the usual way. On a web page, the link itself is doing the same job.
Will I have to redo this later?
Not if the identifier stays the same. That is the part worth getting right first, because identifiers are hard to change and carriers are easy.
Does this apply to batteries?
Batteries have their own rules and their own dates, and they are stricter. Treat this article as being about the general regime.