Can I generate the QR code for the digital product passport myself?
Yes, creating a QR code yourself is technically straightforward: there are numerous free generators that produce a scannable image in a few seconds. The difficulty lies not in the QR code itself, but in what it points to. A QR code for the digital product passport refers to a structured, machine-readable data file with a unique identification code, which must conform to an established format and remain accessible for a specific period — even if your company switches software providers or discontinues a product line.
If you want to set this up yourself, you need to look beyond the image. The question is whether you can generate, maintain, secure and host the underlying data in a way that aligns with what the regulation will prescribe per product group. These are different skills from creating an image.
What a company can handle itself
The source data about your iron or steel — origin, composition, processing steps, certificates — you typically have yourself, or you obtain them from your own supplier. In many cases, a company can organise this data collection work itself, as well as the internal arrangement of who within the organisation is responsible for keeping it current. The choice of whether you build a system yourself or use an existing platform is entirely up to you. In the knowledge base with explanations by topic you will find what the regulation precisely requires from those providing which data, so you can prepare that conversation internally before you make a technical choice.
Where the technology goes beyond a generator
The QR code itself is the easiest step. It becomes more complex with the requirements for the file it points to: a fixed data format, an identification code that is unique and traceable, protection against later alteration, and availability that must not depend on a single server that happens to fail. Companies wanting to build this themselves often find that the first QR code is ready quickly, but that maintenance — new product versions, changes in supplier data, long-term accessibility — becomes a recurring task that does not stop on its own. On the page showing where the data comes from you can read how such a connection is structured in practice, as guidance for those considering a similar system themselves.
What is not yet established
The exact requirements for format, uniqueness of the code and retention period will be worked out per product group in a delegated act under the ESPR regulation. The work plan for 2025-2030 mentions a first delegated act in 2026, with obligations taking effect eighteen months later. Until that text exists, it cannot be said with certainty how long data must remain accessible or which technical format will be mandatory. Anyone building something themselves now is therefore building on assumptions that may change later.
Doing it yourself or outsourcing: the trade-off
Whether building it yourself makes sense depends on your company size, the number of product lines and the extent to which you are already accustomed to maintaining technical systems long-term. A small company with a limited range can get by with a simple solution; a company with many variants and changing suppliers will more quickly run into maintenance work that takes more time than expected. There is no universal answer that applies to every company — the trade-off differs per situation, and for the legal side of it, the official text or a lawyer is the appropriate source. With the free quick-scan that gives an indication in a few questions you can quickly see whether your situation is straightforward or more complex, without needing an account right away.
Do you have questions after reading about specific situations, for example importing from outside the EU or cooperating with multiple suppliers? Then check the collection of frequently asked questions or take the quick-scan to see where your company currently stands.