how do I train my staff to work with the product passport

Training is about reading, linking and passing on, not about technique

Employees do not need to be able to build the digital product passport; they do need to be able to work with it at the point where the steel passes through their hands. That means: scanning or recognizing the QR code, checking whether the data belongs to the correct shipment party, and knowing what to do if a passport is missing, unreadable or does not match the physical product. The training required for this is therefore not about the technique behind the passport — the platform handles that — but about the daily actions on the floor: receipt, storage, resale and delivery.

For whom this is relevant, and for whom it is not

This question particularly concerns employees who have physical contact with the product: warehouse staff, procurement, sales support and logistics. They need to be able to consult the passport and recognize when something is not right. It is less relevant for, for example, financial administration or back office, who have no direct contact with the passport itself. It is also important to distinguish: training employees is something different from drawing up the passport itself. Compiling the data from manufacturer or importer documentation is a task that typically falls to a specialized party or to procurement/quality; the floor mainly needs to be able to work with it, not to fill it in again. For companies with multiple locations there is an additional layer: it is not only a training question but also an organizational one, because the same procedure must work the same way at every site — this is addressed under how you arrange the product passport with multiple locations.

When this becomes relevant is not yet established

There is no fixed date yet on which the digital product passport for steel becomes mandatory. The ESPR (Regulation (EU) 2024/1781) provides the framework in Article 9 and Article 10, but the concrete obligations for a product category such as steel come only with a delegated act per product group. Once such an act is published, there is usually a transition period before the obligation actually takes effect. Until that date is known, there is no legal pressure to train now — but that is precisely why calm preparation now is easier than hasty catch-up later. What can already be done: set up a test environment in which employees can practise with a passport without a deadline hanging over it, see how to have a test version of your product passport made now. More about what there is to do anyway can be found at what you can already do while the rules are not yet definitive.

How you approach the training in practice

Start with the people who encounter the passport first: usually that is the warehouse or receiving department, where incoming steel is checked. First teach them to recognize and scan the QR data carrier, and show them what data is behind it — origin, composition, any certificates. The next step is to have a fixed routine for what happens if something is not right: a QR code that is damaged, a passport that does not match the physical product, or a shipment without a passport. For damaged codes there is a separate explanation of the route to follow, see what you do if the QR code on your steel is damaged. After that, it makes sense to train inside sales on passing passport data to the next party in the chain, so that information is not lost upon resale. Finally, it is advisable to assign someone — often quality or procurement — responsibility for monitoring changes in regulations and industry practice, because a training given once becomes outdated. Anyone who wants to know how the entire process looks in broad outline before the training is set up will find that in the step-by-step approach to the product passport for steel. It is also useful to know that there may already be shared agreements within the sector on how to work with the passport, which makes a training much easier to align with; see whether there is already a sector standard for the steel product passport.

This follows from the articles on the digital passport in the ESPR

The basis for what a digital product passport must contain and how it must be made accessible is set out in Article 9 and Article 10 of the ESPR (Regulation (EU) 2024/1781). Article 9 describes what the passport contains in general terms and what information is processed in it; Article 10 addresses the technical and operational requirements, such as the accessibility of data via the data carrier. These articles say nothing about staff training obligations — that obligation is not explicitly described anywhere — but they do determine what must be recognized and checked, and that is precisely the basis on which internal training is organized.

What you can do now

Training does not need to wait for a final date: start by designating who in the process will be involved with the passport, and practice with a test passport to see how scanning and checking work in practice. This way a working method is already in place once the obligation takes effect, rather than having to hastily improvise it then.

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 does not oblige companies in so many words to train staff. What the regulation does provide is that the digital product passport must exist, must be correct, and must be accessible via the data carrier (usually a QR code) to those who deal with it — see Article 9 and Article 10 of the ESPR (Regulation (EU) 2024/1781). Those obligations rest with the manufacturer, importer or other market operator, but they work in practice down to the shop floor: someone must scan the passport, check it, pass it on or respond to it. Who that "someone" is and how they do it is determined by the company itself. Below therefore not a legal obligation per obligation, but the practical tasks that flow from Articles 9 and 10 for a company with 10 to 100 employees.

Recognizing and being able to scan the passport

Warehouse staff and procurement personnel must know that incoming steel comes with a QR code or similar carrier, and how to scan it. This seems self-evident, but in practice people on the shop floor work with different scanners, apps and phones. One fixed working method — which device, which app, where the scan is stored — prevents everyone from devising their own approach.

Understanding what must be in the passport

Whoever assembles or supplies the passport (often procurement, quality or an administrative function) must understand what data should be in it according to Article 10 of the ESPR. This is not legal knowledge, but practical knowledge: which fields are mandatory, where do those data come from (supplier, own production process, certificates), and what happens if data is missing or incorrect.

Recognizing when something is wrong

An employee who scans a QR code and sees a blank screen, an error message or clearly incorrect data must know what to do: enquire with the supplier, report internally, or set the batch aside. Without an agreement on this, that information often disappears into an oral remark that no one records.

Providing the passport with the sale or further delivery

If you pass on steel or deliver it further, you also pass on the passport — or ensure that the buyer can access it via the QR code. Sales and logistics staff must know that this is part of the order, not a separate administrative step that "still needs to be added".

Where things go wrong in practice

The training is one-off and disappears. One instruction meeting is held during implementation, but new employees never receive that information, and existing employees forget details after a few months.

Only one person knows how it works. Often there is one employee — the quality manager or the buyer — who knows everything about the passport, and the rest of the company only knows that "that one colleague takes care of it". If that person falls ill or leaves, the knowledge is lost.

Scanning happens, but no one checks the content. The QR code is scanned because it has to be, but no one verifies whether the data is correct or complete. Scanning becomes a formality without substantive checking.

Different locations do it differently. In companies with multiple sites, a different approach often emerges per location, without anyone having agreed on it. This is a recognizable problem — see also how do I arrange the product passport if I have multiple locations on the organizational side of this.

A damaged or unreadable code leads to improvisation. If the QR code no longer scans, the warehouse employee improvises a solution — a sticker, a handwritten note — instead of following a fixed procedure. What actually needs to be done in the event of a damaged code is covered in what should I do if the QR code on my steel is damaged.

What you can document

A brief work instruction per role: what does the warehouse employee do, what does the buyer do, what does the seller do with the passport. Brief and concrete, no legal language.
A fixed point of contact or role for questions about the passport, with a backup in case that person is absent.
An induction moment for new employees, as a fixed part of the introduction, not as a separate initiative.
A list of what to do in case of discrepancies: blank scan, missing data, damaged code — who reports this, where, and what happens to the batch in the meantime.
An overview of the steps the company is already taking, so that training aligns with practice rather than a theoretical process. A good starting point for this is how do I approach the steel product passport step by step.
Agreements on what to do now, even while the exact obligations are still being determined — for example, by getting employees used to scanning and checking. See what can I do now while the rules are not yet final for what is practical in this.
Test results from a pilot passport, if available, so that employees can practice with a realistic example before the obligation actually takes effect — see can I already have a test version of my product passport made.
Reference to industry agreements, once they exist, so that the internal procedures align with what becomes standard in the sector — see is there already an industry standard for the steel product passport.

Documenting this takes little time, but ensures that knowledge about the passport does not remain with one person and that new employees do not have to reinvent the wheel.

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.