how do I arrange the product passport if I have multiple locations

The obligation is tied to the product, not to the location

The product passport is an obligation that is tied to the product placed on the market, not to the location where the company is established. This means that a company with multiple locations — for example a head office with a separate production facility, or multiple sales points under one legal entity — does not need to arrange the passport separately per location. The obligations under Article 27 of the ESPR (Regulation (EU) 2024/1781) rest with the manufacturer as a market operator, and this role is not linked to a specific building or address, but to the party responsible for placing the product on the market. Those producing or trading steel in multiple places can therefore in most cases work with a single established procedure, as long as that procedure delivers the correct, current data per product.

For whom this applies, and where it stops

This applies to companies that under one legal entity or under affiliated legal entities produce, process or trade the same type of steel products at multiple locations. The question then is whether a single passport process can suffice for products that are technically and administratively related to each other. It does not automatically apply to situations where different locations are legally separate from each other — for example independent subsidiaries, franchisees or separate trade names with their own registration. In those cases, each legal entity can be regarded as its own market operator, with its own responsibility for the products it places on the market. Nor does it apply to products that are sold through multiple locations but originate from different manufacturers or importers: each passport remains tied to the specific product and the party responsible for it, regardless of which sales point the customer ultimately receives it through. Those in doubt about whether their own locations fall under one responsibility or not are well advised to clarify this first, as it determines whether a single central approach is sufficient or not.

When this becomes relevant

There is no fixed date yet for when this obligation takes effect. What is certain is the procedure: the ESPR is the framework regulation, and the specific obligations for particular product groups — including steel — will only come with a delegated act that is established per product group. For steel, that act does not yet exist. Once it is published, there will still be a period before the obligations actually take effect. Until then, there is no legal obligation to operate a passport now, but nothing prevents a company from already arranging its own organisation — including the distribution across locations — in such a way that a passport can later be connected to the correct product streams without difficulty.

How to approach this in practice

The first step is to gain clarity on the legal structure: which locations fall under which legal entity, and who is the manufacturer or importer for which product within the meaning of Article 27. Next, it is necessary to determine whether the product information required for the passport — origin, composition, processing, certificates — is recorded centrally or per location. For companies with multiple production locations under one legal entity, a central approach is often the obvious choice: one system in which data per product or production batch is collected, regardless of which location the material has been processed at. For companies with separate legal entities per location, it makes sense for each legal entity to establish its own process, possibly with a shared standard so that the data is mutually exchangeable. After that, it is wise to review what internal data and systems are already in place, and how these align with what the passport will later require — how do I approach the steel product passport step by step provides a sequential approach for this. For companies that want to experience how this works in practice before the obligation takes effect, there is the option to have a test version of the product passport created now, which will also immediately show whether the current establishment structure and data flows are already sufficient for this.

What this is based on

The obligations for manufacturers are set out in Article 27 of the ESPR (Regulation (EU) 2024/1781), which specifies who is responsible for drawing up and keeping the product passport up to date. What the passport itself must contain and how it works technically is set out in Article 9 (digital product passport) and Article 10 (requirements for the digital product passport) of the same regulation. These articles link the obligation in each case to the market participant and to the product, not to a physical location, which is the basis for the conclusion that an establishment structure in itself does not require a separate passport process, as long as the responsible legal entity is clearly identified.

Anyone who wants to check now whether their own product will fall under these rules in future can verify this via does the digital product passport apply to my steel, and anyone wishing to prepare their organisation in advance is well advised to also look at what can already be done while the rules are not yet final.

What this is based on

The regulation itself can be found on EUR-Lex. We provide references for each statement; you do not have to take our word for it.

What you must concretely do

What is expected of you

The ESPR links obligations to the role a company has — manufacturer, importer or distributor — and not to the number of establishments that a company has. Article 27 of the ESPR (Regulation (EU) 2024/1781) sets out the obligations of manufacturers, and those obligations are linked to the product, not to the location where the product is made, stored or processed. For a company with multiple establishments, this is primarily an organisational matter: who within the company ensures that each establishment works with the same, correct passport data.

One coherent passport per product, regardless of establishment

Article 9 of the ESPR (Regulation (EU) 2024/1781) describes the digital product passport as a collection of data linked to a specific product or product model. This means that the passport does not differ by establishment: a batch of steel that is manufactured or imported at one establishment and processed, resold or stored at another establishment should in principle remain linked to the same passport. For a company of 10 to 100 employees with, for example, a production location and a separate trading establishment, this means that passport data must be managed centrally, even if operational activities are dispersed.

Ensure that the QR data carrier follows the product, not the location

Article 10 of the ESPR (Regulation (EU) 2024/1781) sets requirements for how the data of the digital product passport must be accessible, via the carrier attached to the product. When a product is moved between establishments — from storage to processing, from processing to sale — the link between product and passport must remain intact. In practical terms, this means that a company with multiple locations needs a foolproof way to ensure that the data carrier follows the product and is not accidentally disconnected during internal transfers between establishments.

Designate unambiguous responsibility within the company

Article 27 of the ESPR (Regulation (EU) 2024/1781) places the obligations on the manufacturer, and on import on the importer. In a company with multiple establishments, it is common for different departments or locations to be involved in part of the process: procurement at one location, processing at another, sales elsewhere again. Who supplies or checks which data is an internal matter — the regulation itself places the obligation on the legal entity acting as manufacturer or importer, not on a specific establishment of that entity.

Where things go wrong in practice

A few situations regularly occur in practice at companies with multiple establishments.

A first situation: one facility works with a different system or different templates than another, resulting in two passports for what is actually the same product containing divergent data. A second: when inventory is moved internally between facilities, the link between physical product and QR code is lost, for example because a label comes loose or is not transferred when repacking. A third situation arises when a central purchasing department receives passport data from the manufacturer, but does not consistently pass that information on to the facilities that further process or sell the product — with the result that the selling facility does not know which data already exist and which are still missing. A fourth: in the case of a merger or takeover of an additional facility, it becomes unclear who is henceforth responsible for maintaining passports for inventory originating from the acquired facility. And a fifth: different facilities each use their own point of contact with a supervisory authority, so that during an inspection it is not immediately clear who holds the complete passport data for a particular batch — whereas what does a supervisor ask during an inspection on steel precisely shows that overview and quick availability of data count.

These situations are not a matter of bad faith, but of a lack of coordination between facilities that have each developed their own working method before the product passport came into view.

What you can document

For a company with multiple facilities, it is worthwhile to arrange a number of things in writing, so that responsibilities do not depend on who happens to be there at any given time:

An internal role allocation: who within the company is ultimately responsible for creating, checking and keeping passports up to date, and which facility provides which part of the data.
A standard process for internal transfers: how is the link between product and QR data carrier monitored when inventory moves from facility to facility, including what happens if a label is damaged — see also what should I do if the QR code on my steel is damaged.
One central storage location for passport data, accessible to all facilities, so that each location does not maintain its own, possibly divergent version.
Agreements with suppliers and manufacturers about what data they supply and to which facility, so that duplication or gaps are prevented.
A training plan for employees at each facility who deal with the passport, from warehouse to sales — how do I train my staff to work with the product passport provides a starting point for that.
A joint action plan that uses the same starting point for all facilities, rather than each location reinventing the wheel — how do I approach the steel product passport step by step is a starting point for that.

These agreements are an internal organizational choice and not a legal obligation per se, but they reduce the risk that distribution across multiple facilities leads to inconsistent or incomplete passports for what is essentially the same product.

This is not legal advice. This page provides general information about the legislation that this platform deals with. We do not know your situation. If you are in doubt about your own case, consult a lawyer or the competent supervisory authority.

Written with AI based on the sources above, verified by a human on 2026-09-05. Is anything incorrect? Let us know — corrections are given priority.