Digital Product Passport: Built to last

In the spring of 2036 an upholsterer gets an armchair on his bench. The cover is worn through, the frame is still sound. Under the seat there is a small QR code. The workshop that built the chair in 2026 closed five years ago.

He scans the code and the digital product passport opens. At the top it says “Archived on 30 June 2031”, and below it everything he needs for the job, because the workshop published its repair data openly: the foam and its density, the fibres of the old cover, how the frame is glued and screwed together. The viewer checks the signature in his browser, and it holds.

A product passport has to be built to last that long. The Ecodesign for Sustainable Products Regulation (ESPR) requires it to remain available for the prescribed period, including after an insolvency, a liquidation or the company's withdrawal from the EU. At Transpareo this case is already built, for everything a passport shows publicly. We show how with the armchair from the workshop, from its first passport to the day on the upholsterer’s bench.

The harder part is what a passport shows only to certain readers. The law wants that data, too, kept for years and still open to only a few, even once the company that decides who may see it is long gone.

A passport is changed only by its company

The ESPR ties the right to change a passport to the access rights the delegated act for the product group lays down. In Transpareo a passport is changed by the company that issues it, and by whoever it gives the rights to. Every change becomes a new, signed version, chained to the one before: Transpareo Proofchain. If the workshop corrects the density of the foam in 2028, a reader sees the new value, the old one and the day of the correction.

A published version can no longer be changed unnoticed, by us included. How this is secured is explained in our article on signatures in the product passport.

When the manufacturer stops

When a company winds down, its customers keep finding its passports, unchanged, even while its workspace is paused. Once the workspace is closed for good, Transpareo moves the published passports into a static archive:

• The same addresses. Every printed QR code and every GS1 link still leads to the passport, at every address the workspace had.
• The same data. The signed versions, the event log, the images and the technical documents sit in the archive unchanged, as the public last saw them. Every page carries the line “Archived on” with the day of the closure.
• No new version. The private key the company signed with is deleted. Its public half stays, so anyone can keep checking the old signatures. After that nobody can sign anything in the company’s name, us included.
• Ten years from the closure. That is how long the archive serves the passports. We can extend the period, and it can never be shortened.

The workshop remains the issuer. Its name is on every page and its signature on every version. Transpareo keeps the addresses reachable and adds nothing.

The archive shows the passport as its company last issued it, and it can do nothing else.

So in 2036 the upholsterer sees exactly what the workshop showed publicly in its passport until 2031, with the correction from 2028 and every version before it.

What you take with you

Should you ever leave Transpareo, you take your products, components and passports to a provider of your choice, with all their properties, the restricted ones included, and all their texts in every language. The export delivers them as a spreadsheet (CSV or Excel), linked data (JSON-LD) or tables for a database (SQL), as our guide to digitising product data shows. Your grants to certain readers belong to the workspace; you set them up again at the new provider.

In addition you receive the DPP web archive, with the same public part as the archive after a closure: every passport page in every language, every signed version, the event log, the images, the documents and the public keys. The DPP web archive also includes our open-source viewer Transpareo Time Machine.

The DPP web archive runs on any plain web server, with no database and no Transpareo. A server configuration for short addresses and GS1 links is included.

You download both while your workspace runs. Put the archive up at your new address and give us that address before you delete the workspace. Every old address of your passports then redirects there.

Transpareo Vault: what EU registration adds

The static archive shows what was public. A product passport also holds data that only certain readers may see, and for that there is Transpareo Vault.

Once your passports are registered with the EU registry, Transpareo writes every version in full, with all restricted data, into a separate write-once archive for ten years. Until that period has run out, nobody can change or delete anything there, neither you nor we. An authority finds the data there even when the company has long ceased to exist.

Vault is built and takes effect with registration, because the prescribed retention starts with it. The registry itself keeps the registration data for ten years where the law for the product group sets no other period. What the entry asks of you is set out in our analysis of the registry regulation.

What the law still leaves open

For restricted data the law asks two things. The passport is to stay, for batteries even after the responsible economic operator ceases to exist, and its protected parts are for only a few readers: for batteries, the act on legitimate readers takes as its yardstick limiting the access to and processing of commercially sensitive information to the minimum necessary, and under the ESPR the Commission has to take into consideration the protection of confidential business information. What the law limits is the access; the passport has to keep the data itself. How Transpareo protects it is set out in our article on trade secrets in the product passport.

While the company exists, the two duties fit together: it holds the data and decides who sees it. At Transpareo a company’s grants end with the company. Both archives carry only the public part, only authorities receive data from Transpareo Vault once the company has gone, and before registration restricted data ends with the closed workspace.

For the data itself the ESPR makes provision: the company has to make a back-up copy of the passport available through a passport service provider. The regulation does not say who checks, once the company has gone, whether a reader is entitled to restricted data, or who hands it over from that copy. Who may see which data is set by the delegated act for each product group, and under the ESPR none has been adopted yet, furniture included.

Batteries are furthest along: for the act that specifies who counts as a person with a legitimate interest, the Commission published a draft in October 2026 and takes feedback until 16 November 2026. It names repair shops, recyclers and the purchaser of a battery among others, but leaves open how they prove their claim, who checks it and what applies once the manufacturer is gone.

In our feedback to the Commission we welcomed the draft and proposed an owner code handed over with the sale papers, with which the purchaser of a battery could give a workshop access, limited in time and revocable at any moment. On its own the code does not keep the data there once the manufacturer is gone, keep a revocation current everywhere or see that someone delivers the data safely. Whether the act takes it up is for the Commission to decide.

Had the workshop shown the frame’s construction only to repair shops, the upholsterer would not find it in the archive in 2036. As long as the law leaves open who releases such data afterwards, whatever a passport should still show once its maker is gone belongs in its public part.

A ten-year passport needs a ten-year provider

A promise that runs for ten years is worth as much as the company that makes it. Transpareo has been self-financed from the first day, with no investors working towards a sale. 51 per cent of the share capital of Transpareo AG is held by the non-profit Transpareo Foundation in Zug, which is overseen by the Swiss Federal Foundation Supervisory Authority. A foundation cannot sell its assets, so the majority of Transpareo can never change hands. There is more on our page about the company and its foundation.

We still build the passport for the day we might no longer be here. Every version can be checked against public keys without us, all the data of your passports can be exported, and with the DPP web archive you also hold a complete copy of the public part in your own hands. Building a passport that works without its provider was the more demanding choice. For data a repairer, a recycler or an authority should still be able to rely on in ten years, we think it is the right one.

Why the start counts

A passport’s history begins with its first version, and every correction, every new batch and every event is added to it, signed and dated. Because the workshop published in 2026, the upholsterer reads the armchair’s whole story in 2036.

A signed history cannot be backdated. It begins on the day you publish.

For e-bike and electric vehicle batteries and for industrial batteries over 2 kWh, the passport is mandatory from 18 February 2027, as our overview of the battery passport deadline shows. For furniture it is expected from 2029, and the dates of the other sectors are in the industries reference.

What takes months is gathering the data. With Transpareo Upstream you request that data directly from your suppliers, and once you have it, the passports are published in a few minutes.

Your plan can be cancelled monthly. Transpareo builds every passport you publish so that its public part keeps answering, whether you stay, move or one day stop. The armchair from the workshop got its passport in 2026, and it still carries it in 2036.