Flip over a computer power supply: a jumble of symbols — CE, FCC, GS, a TÜV logo. For decades these markings have been the language of product conformity. The digital product passport (DPP) is a qualitative leap: the question is no longer what the manufacturer prints on the product, but what it can prove in a registered, verifiable way. The following story shows why that became necessary.
The case of the printed CE sticker
Zsolt Takács, owner-CEO of ESGinfo.hu and ReadyPass, recalls an import case from about ten years ago: customs inspection found that lamp fixtures arriving from China lacked the CE marking. The Chinese supplier's proposed fix? They would e-mail a sheet of printed CE labels — just stick them on at customs.
That, of course, is not how it works: the marking is affixed by the manufacturer, who thereby guarantees conformity. A product manufactured outside Europe may only enter the EU if it already carries these markings. The shipment never reached the market.
What few people know: CE is self-certification
In most product categories, CE marking is self-certification: the manufacturer itself declares that the product meets the applicable requirements. For a power supply that means: no electric shock, cut-out on overcurrent, no interference with radio reception or pacemakers, no overheating. Remember when a ringing mobile phone made the loudspeaker chirp? That was precisely the era when electromagnetic compliance was less regulated — and less respected.
The auditor's lesson: businesses typically start caring about a requirement when the law obliges them to — and really start caring when fines arrive.
The line between trade secrets and mandatory data
Why does it take regulation at all to learn what is inside a product? Because manufacturers — understandably — did not want to give away their recipes. For chemicals, this played out over the past decades through three regulations:
| Regulation | What it governs |
|---|---|
| CLP | What must be printed on the product (not what the manufacturer would like) |
| RoHS | Which hazardous substances must not be in the product (e.g. lead) |
| REACH | Which substances may not be placed on the market, and what must be registered |
The DPP extends the same logic to sustainability data: the manufacturer does not have to disclose the full recipe, only the key information defined by law — critical raw material content (copper, cobalt, manganese), recyclability, carbon footprint, and the manufacturer's identification data. The question is no longer what a company wants to publish, but what it must.
Three fundamental differences between the DPP and CE
1. Registered operators. A DPP can only be issued by a registered economic operator: the company must register with the EU, create an account, and keep its product passports linked to its own identifier. CE required no notification — "you just put it on the label". 2. Retention obligation. DPPs must be stored by law and remain retrievable 5–10–15 years later. Importantly, the EU does not store the passports — the registry only holds references; availability must be guaranteed by the business itself (in-house or outsourced). That is a serious data-retention, security and redundancy exercise. 3. Verifiability. Anyone can print a sticker — the story above proves it. Behind a DPP stand standardised unique identifiers (EN 18219), standardised data carriers (EN 18220) and cryptographic data authenticity (prEN 18246): a forgery is machine-detectable.
What should a manufacturer or importer do now?
- Inventory your current markings and the evidence behind them — self-certification is only worth anything with documented testing.
- Build a product compliance matrix: which requirements apply in which markets. Legal, technical, quality and commercial specialists build this best together.
- Importers, remember: you are liable for the conformity of what you bring in — see our article on importer obligations in the EU.
Frequently asked questions
Does the DPP replace CE marking?
No. CE remains the marking of technical-safety conformity; the DPP makes sustainability and lifecycle data accessible and verifiable. The two live side by side.
Who can issue a DPP?
A registered economic operator — typically the manufacturer; for products made outside the EU, the importer or authorised representative carries the responsibility.
How long must the product passport be retained?
It varies by product group, but the principle is: throughout the product's lifecycle (typically on the order of 10 years) it must be producible — authorities may request it at any time.
The sticker era is over. ReadyPass creates trusted digital product passports with eIDAS-compatible signatures, standardised identifiers and long-term retention — so your compliance rests on verifiable data, not claims.
