must the product passport also work without internet connection

What you must concretely do

What is expected of you

The ESPR describes the digital product passport as a system in which data is made available via a data source, retrieved via a unique identification code and a data carrier such as a QR code. Whether the data itself must also be able to be consulted offline is something the text of the regulation itself does not make an explicit statement about in the articles describing the passport and the web portal. What is certain, however, is a number of requirements that relate to the way in which the passport operates technically.

The data must be retrievable via a data source

Article 10 of the ESPR describes the requirements for the digital product passport, including that data must be accessible via a data carrier that refers to a data source. This points to a system that operates on a connection: the QR code itself does not contain data, it only points to where the data is stored. For a metal processor with between 10 and 100 employees, this means in practice that the passport is an online service, not a file stored on the product itself. Those who make agreements about this with a supplier or customer are well advised to establish who manages the data source and how long it will remain accessible — something more can be read about at how long must a product passport remain available.

The register keeps a copy of basic data

Article 13 of the ESPR governs a register of digital product passports at EU level. This register is intended for oversight and contains basic data, not the full passport. For a company placing steel products on the market, this means there are two places where data ends up: the company's own (or outsourced) data source, and the central register. What exactly must be included in that register and who enters it is set out on the page on the register of digital product passports and what you put in it.

The web portal makes data accessible, but does not replace the data source

Article 14 of the ESPR describes a web portal through which data from the digital product passport can be consulted. This portal is an additional access route, not a replacement for the direct link between QR code and data source. For the practice of a trading company, this means that a customer can access the same information in two ways: by scanning the code on the product, or via the portal. Both routes require an active connection to a data source on the internet.

Where things go wrong in practice

A few situations in which the question "does this also work without internet" goes wrong in practice:

A warehouse with poor coverage. Steel is often stored outdoors or in large halls where mobile coverage is inconsistent. A worker on the production floor who wants to consult a passport will then encounter a blank page without it being clear whether that is a problem with the passport or with the network.

Confusion between "the QR code" and "the passport". Some companies think the passport is in the QR code, like a barcode with a product code. That is not the case — the code refers to a data source. Anyone wishing to explore this further will find more explanation at how does the QR code for the product passport get onto my steel.

Assumptions about local storage. A construction company that processes steel for an extended period at a construction site without internet connection sometimes assumes that a PDF or photo of the passport downloaded once is sufficient as proof. Whether that is acceptable as a replacement for the live data source is not something the ESPR text itself makes a statement about.

System that ceases to exist when the company closes. When a manufacturer hosted its own data source and the company shuts down, access to the passport may disappear entirely — with or without internet. That risk is separate from the question of "offline or online", but in practice it is often confused with it. See also what happens to the product passport if a company closes.

Incorrect link with the ERP system. A company that attempts to link the passport to an internal inventory system sometimes runs into the assumption that this link must also work offline because the internal system does. The link to an externally queryable data source is a different layer than internal business operations; more on this at can you link the product passport to an ERP or inventory system.

What you can document

• Agreements with the party hosting or that will host the data source regarding availability and downtime.
• An overview of where in the business process a passport must be consulted without reliable internet connection (for example at a construction site or in a warehouse), so that this risk is known internally.
• Documentation about which identification code belongs to which product or batch, independent of whether it is consulted online or offline — see also how do you give each product a unique identification code and do you register steel per batch or per unit.
• A documented procedure for what happens if a customer or supervisor cannot consult a passport at the time of inspection.
• Technical documentation on the format in which data has been provided, so that in the event of a future requirement regarding offline availability it is clear what is already established — more on this at in what format must data be provided for the product passport.

As soon as the European Commission publishes a delegated act that specifically addresses iron and steel, it may contain a more specific requirement regarding offline availability. Until then, this is a matter on which the framework regulation itself makes no direct statement, and it remains necessary to monitor this page for updates once that clarity is available.