Digital Product Passport for consumer goods (FMCG)

Not as a blanket rule. It is worth being precise about which parts are already law. The Packaging Regulation has applied since 12 August 2026. The harmonised label follows in August 2028 at the earliest, recyclability and recycled content in 2030 at the earliest. Detergents get a real digital product passport, from 23 September 2029. Food and drink are governed by labelling law, which has no passport act. Everything else in a consumer-goods range has no passport date yet. In Transpareo you can still create your passports today.

What it requires is a harmonised label on material composition with EU-wide pictograms. Where applicable, a QR code or another open digital data carrier comes with it. Reusable packaging and deposit systems carry their own markings. An implementing act sets the design and the formats. It was due by 12 August 2026 and has not been adopted. That is why the date can move. Build the underlying data now anyway, because it stays valid if the pictogram changes.

Yes. The duty attaches to placing on the market, wherever the goods were made. An importer of a private-label range answers for the label and the packaging data just as the manufacturer would. From 2029 it also makes sure every detergent has its passport and its registry entry. So the recycled-content certificate and the recyclability assessment have to arrive with the shipment. Settle it in the purchasing contract, because that part takes months. With a supplier request in Transpareo, your supplier fills in the evidence directly.

Almost every FMCG article already has one, and that is the easy case. Transpareo turns it into a GS1 Digital Link. So one code carries the number for the till and the way to the passport. Where an article has no GTIN, Transpareo issues a unique identifier of its own, and the QR code leads to the passport just the same. More on the choice in why GS1 Digital Link is the right standard.

Only partly, and the rules differ by product. For food the mandatory particulars appear on the package. A QR code adds to the label there. The new Detergents Regulation goes further. The content figures for surfactants, phosphates and soap may sit on a digital label alone. Identification and safety information stay on the pack. Use the digital label for what no longer fits on the pack.

For most FMCG articles the passport belongs at product level. That is where the composition, the labelling and the certificates live, and the detergent passport is per model anyway. Batch level pays for itself where a detail varies by production run. That may be a recycled-content share that differs between suppliers, or a plant-specific certificate. A recall that has to reach three lots is another reason. Transpareo keeps passports per model, batch and item on the same template. You start at product level and add batches where a line needs them.

No EU rule requires a carbon footprint in an FMCG passport today. Many brands publish one anyway, because retail customers ask for it in their own reporting. If you do, name the method you used. A figure without a method cannot be compared and invites the suspicion that it was chosen to flatter. Transpareo keeps the value as an ordinary field. The methods are compared in carbon footprint in the DPP.

Consumers need the ingredients, the allergens, the sorting instruction and the disposal information. Retail customers and auditors want the recyclability assessment, the certificates and the declaration of conformity. Authorities need the technical documentation. In Transpareo every data field has its own visibility. The public tier appears without a login, and everything else sits behind logged access. So one code shows three different views of the same passport.

The central registry has been running since 20 July 2026. Registration follows the act that requires a passport for your category. For detergents the economic operator uploads the product and operator identifiers before placing on the market, from 2029. For food and drink there is no entry today. Only a verified company can register. Today your company makes the entry itself, and a service provider cannot do it for you yet. We expect that to change. Transpareo prepares what the entry asks for, from the product identifier to the passport address. Background in our analysis of the registry regulation.

In this industry the catalogue is the bottleneck. A mid-sized FMCG range is thousands of articles, each with a pack, a closure and a label. The recycled-content and recyclability data sits with three or four packaging suppliers. Getting that data flowing takes a purchasing cycle. The first import shows you which fields nobody has ever recorded. So start with an inventory of the packaging data. Once the data exists, Transpareo publishes the passports in a few minutes.