Digital Product Passport for fast-moving consumer goods (FMCG)

Not as a blanket rule, and it is worth being precise about which parts are already law. Packaging duties under the PPWR apply since 12 August 2026, with labelling in 2028 and recyclability and recycled content in 2030. Detergents get a real digital product passport from 23 September 2029 under Regulation (EU) 2026/405. Food and drink are governed by labelling law, not by a passport act. Everything else in a consumer-goods range has no passport date at all yet.

Article 12 requires harmonised labelling on material composition and sorting, based on EU-wide pictograms, accompanied where applicable by a QR code or another standardised, open, digital data carrier. Reusable packaging and deposit systems carry their own markings. The design, technical specifications and formats come from an implementing act the Commission has not yet adopted, which is why the date attached to the labelling duty can move. Building the underlying data now costs you nothing if the pictogram changes later.

Yes. The duty attaches to placing on the market, not to manufacturing. An importer of a private-label range answers for the label, for the packaging data and, from 2029, for the detergent passport exactly as the manufacturer would. In practice that means the recycled-content certificate and the recyclability assessment have to arrive with the shipment, not on request afterwards. Settle it in the purchasing contract; that is the part that takes months.

Almost every FMCG article already has one, and that is the easy case - the identifier in Transpareo becomes a GS1 Digital Link, so the same code serves the till and the passport instead of two codes on one pack. Where an article has no GTIN, the passport carries a unique Transpareo identifier and the QR code leads to it just the same. More on the choice in why GS1 Digital Link is the right standard.

Only partly, and the rules differ by product. Food labelling keeps its mandatory particulars on the physical label; a QR code adds to it rather than replaces it. The new Detergents Regulation goes further and allows a defined part of the information to live in the digital label only, while identification and safety-relevant details stay physical. Treat the digital label as a place for what does not fit, not as a way to shrink a pack’s printed face.

For most FMCG articles the passport belongs at product level, because that is where the composition, the labelling and the certificates live. Batch level pays for itself where a claim varies by production run - a recycled-content share that differs between suppliers, a plant-specific certificate, a recall that must reach three lots and not the whole line. Transpareo supports model, batch and item passports on the same template, so you can start at product level and add batch granularity for the lines that need it.

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, say which method you used - a figure without a method is not comparable and invites the accusation that it was chosen to flatter. Transpareo carries it as an ordinary property with a source note; 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, visibility is a property of every data field, so the public tier appears without any login and everything else sits behind logged access - one passport, one code, three different views.

The central register has been operating since 20 July 2026, with Implementing Regulation (EU) 2026/1778 setting out how it works, and detergents are among the product groups it is built to carry. Registration follows the act that mandates a passport for your category, so for detergents it becomes relevant towards 2029 and for food and drink not at all today. Only the economic operator placing the product on the market may register it (ESPR Art. 13(4) and (5)); a service provider cannot do it for you unless the act for your product group provides for it. Transpareo prepares what the entry asks for - product identifier, operator identifier, passport address and fingerprint - so you complete the entry yourself once the register’s interface is final; the Commission is examining whether service providers may do this in future. Background in our analysis of the register regulation.

The technology is never the bottleneck in this industry; the catalogue is. A mid-sized FMCG range is thousands of articles, each with a pack, a closure and a label, and the recycled-content and recyclability data sits with three or four packaging suppliers. Getting that data flowing takes a purchasing cycle, and the first import is where you discover which fields nobody has ever recorded. Start with the packaging data inventory - the passports themselves are set up in Transpareo within days once the data exists.