
Digital Product Passport for food
The Digital Product Passport for food is voluntary, the label and the wine e-label are mandatory. From December 2026, origin down to the plot joins them.
Where Transpareo supports you
Food carries no passport duty, because the Ecodesign Regulation excludes it. Your duties come from food, packaging and deforestation law. Transpareo is the DPP platform on which you maintain the data for them once and show it behind a QR code. The cards point to the sections with the details. To tick things off, use the food checklist.
Your product needs a code that leads from the shelf to all its details. Transpareo builds it from your GTIN as a GS1 Digital Link, per product, batch or item.
Every new recipe changes ingredients and nutrition values. In Transpareo they are fields of their own, and new batches show the new values the same day.
The 14 allergens stand out on the pack. Transpareo also keeps them as a field, so your online shop and the passport show the same information.
Wine may show ingredients and nutrition behind a QR code, without advertising or user data. Transpareo shows no advertising there and does not track readers in the browser.
Cocoa, coffee, soya and four more commodities need the coordinates of their plots. Transpareo keeps them in fields, and you file the due diligence statement with the EU yourself.
The farm knows the coordinates, often several steps before you. With Transpareo Upstream your suppliers and theirs fill in the details, and you review every value.
The organic certificate, the fair-trade mark and the lab report belong to the product. In Transpareo they sit beside it as documents, public or only for the readers you admit.
A product on shelves in Milan, Lyon and Kraków needs three languages. Transpareo translates your details into 40 languages, and you review the result.
A recall concerns particular batches. In Transpareo you suspend their passports, and every earlier version stays retrievable and signed.
No passport duty for food, but plenty of data
No law requires a digital product passport for food. Yet food law already asks for much of the data a passport carries. With Transpareo you maintain that data once and show it behind a QR code, in the reader’s language.
Where the law stands
The Ecodesign Regulation is the basis of the product passport. It expressly excludes food and feed. So for food there is no delegated act, no passport deadline and no entry in the EU registry.
The duties on this page come from three other fields of law. Food law governs the label, packaging law the packaging and the Deforestation Regulation the origin. Most of it applies already.
What already applies today
The Food Information Regulation has applied since 13 December 2014. Since then every prepacked food has carried its mandatory particulars on the pack. The 14 allergens are emphasised in the ingredient list. Since 13 December 2016 the nutrition declaration has been mandatory too.
A food label has carried a small, fixed dataset for more than ten years.
Whoever sells online shows the same information before the purchase is concluded. In Transpareo it sits in one place. Your online shop reads it through the API from the same record as the passport.
Wine leads the way
Since 8 December 2023 wine has carried an ingredient list and a nutrition declaration. Both may be given by electronic means, usually through a QR code. The energy value and the allergens then stay on the label.
The page behind the code follows fixed rules. It may not collect or track user data. And it may not show the information next to marketing.
The EU wine package has applied since 18 March 2026. The Commission may now set a common symbol for the reference to the e-label. From 19 September 2027 ingredients and nutrition values are no longer required for wine intended solely for export.
Transpareo shows no advertising behind the passport and does not track readers in the browser. What you put on the page remains your responsibility as the operator.
Then the supply chain arrives
From 30 December 2026 the Deforestation Regulation applies. It covers cattle, cocoa, coffee, oil palm, rubber, soya and wood. Whoever first places such products on the EU market files a due diligence statement. It includes the geolocation of all plots where the commodity was grown.
Plots above four hectares need a polygon, except for cattle. Micro and small enterprises follow on 30 June 2027. Whoever processes or trades further files no statement of its own. It records where the goods came from and where it delivers them.
From 30 December 2027 soluble coffee and frozen cattle tongues join. Packing that carries another product falls outside the regulation.
What the packaging requires
The Packaging Regulation has applied since 12 August 2026. Its labelling comes later. The harmonised sorting label applies from 12 August 2028 at the earliest. It hangs on implementing acts the Commission has not adopted yet. Reusable packaging carries a label and a data carrier of its own from 12 February 2029 at the earliest.
What you find on this page
Further down are the dates, the roles and the data that food and deforestation law ask for. Then come the checklist to download, the official sources and the questions food manufacturers ask most often. Where a term is underlined with dots, a click shows the wording of the law.
From the rules to the passport
The picture sets out the rules for your food in grey. Teal is the data you maintain for them anyway. Blue is the Transpareo product passport, which shows every reader their part of it.
The three biggest hurdles in practice
- Everything varies by batch: nutrition values shift with the harvest, origin with the supplier. A recall always concerns particular batches. So a single product page does not describe what someone bought. In Transpareo you keep the passport per batch.
- The coordinates sit several steps away: the farm where the commodity grows knows the geolocation. It travels through traders who pass it on only when the contract says so. That negotiation often takes longer than introducing any software. With a supplier request in Transpareo you reach your supplier’s suppliers too.
- Recipes change faster than artwork: a new recipe brings new nutrition values, perhaps new allergens and a new print run. In Transpareo new batches show the new values the same day. Earlier batches keep the values they were made with.
More on this: The DPP forces digitisation and How data flows into the passport.
Regulatory timeline for food
The key dates of the rules that apply to food or are still to come, in order. Dates that hang on acts not yet adopted are marked as such.
- 13 December 2014Food information rules apply
Regulation (EU) No 1169/2011 applies. Prepacked food carries its mandatory particulars on the pack. The 14 allergens stand out in the ingredient list. For distance selling the same information is available before the purchase.
- 13 December 2016Nutrition declaration becomes mandatory
Energy value, fat, saturates, carbohydrate, sugars, protein and salt now appear on most prepacked food. The label carries a small, fixed dataset.
- 1 January 2022Organic regulation applies
Regulation (EU) 2018/848 replaces the earlier organic rules. It governs the EU organic logo, the code number of the control body and the operator certificate. Every organic claim on a label or in a passport rests on it.
- 8 December 2023Wine e-label
Wine now carries an ingredient list and a nutrition declaration. Both may be given by electronic means, usually through a QR code. The energy value and the allergens stay on the label. The page behind the code shows no advertising and collects no user data.
- 19 December 2025EUDR postponed a second time
Regulation (EU) 2025/2650 simplifies the Deforestation Regulation and moves its dates again. Only the first operator files a due diligence statement. Micro and small primary operators in low-risk countries file a one-off simplified declaration.
- 18 March 2026EU wine package in force
Regulation (EU) 2026/471 amends the wine rules. The Commission may set a common symbol that points to the e-label. From 19 September 2027 ingredients and nutrition values are no longer required for wine intended solely for export.
- 12 August 2026Packaging regulation applies
Regulation (EU) 2025/40 applies. The harmonised sorting label follows on 12 August 2028 at the earliest. The label and data carrier on reusable packaging follow on 12 February 2029 at the earliest. Both hang on implementing acts the Commission has not adopted yet.
- 18 September 2026List of products recast
Delegated Regulation (EU) 2026/2102 recasts the list of the Deforestation Regulation. Soya beans for sowing drop out. Packing that supports or protects another product is expressly excluded, and so are samples.
- 30 December 2026EUDR applies to most operators
Cattle, cocoa, coffee, oil palm, rubber, soya and wood may only be placed on the market deforestation-free and legally produced. The first operator files a due diligence statement with the geolocation of the plots.
- 30 June 2027EUDR for micro and small enterprises
Natural persons and micro and small enterprises follow six months later. They must have been established as such by 31 December 2024. Wood covered by the old Timber Regulation keeps the earlier date.
- 30 December 2027Soluble coffee joins
Coffee extracts and soluble coffee now fall under the Deforestation Regulation. So do frozen cattle tongues and further products made with palm oil.
- No act plannedFood stays outside the ESPR
The Ecodesign Regulation excludes food and feed. No delegated act and no mandatory product passport will come for food. Everything on this page follows from food, packaging and deforestation law.
Who is affected?
Duties for food: what falls on each economic operator on the way to the market.
The operator responsible is the one under whose name the food is marketed. It makes sure that ingredients, allergens and nutrition values are present and right. That covers every voluntary claim next to them as well. In Transpareo you maintain these details once, for the online shop and the passport.
If that operator is established outside the EU, the importer carries the responsibility. For cocoa, coffee or soya it is usually also the first operator under the Deforestation Regulation. It then needs coordinates from farms several steps away. With a supplier request in Transpareo, its suppliers fill them in themselves.
Retail does not supply food it holds to be non-compliant. It does not alter the information that accompanies a food. In the shop, customers scan the code. So the link on the pack has to outlast the promotion it was printed for.
Whoever first places one of the seven commodities on the EU market files the due diligence statement. For that it needs the geolocation of the plots. A certificate does not replace the coordinates. Whoever processes or trades further files no statement of its own and records where the goods came from.
What belongs in a DPP for food?
Data fields of a voluntary passport for food, including data current EU law already asks for.
This covers raw-material origin, processing sites and EU origin marks such as the protected designation of origin. For the seven commodities of the Deforestation Regulation, origin becomes a coordinate. Above four hectares a polygon describes the plot, except for cattle.
The mandatory nutrition declaration lists energy value, fat, saturates, carbohydrate, sugars, protein and salt. The values apply per 100 g or 100 ml, optionally per portion as well. They are recalculated after every change of recipe. In Transpareo they are fields of their own with a unit.
The 14 allergens are emphasised in the ingredient list. Font, style or background colour sets them apart from the rest of the text. On wine they stay on the label, even with an e-label. The same care pays off for every food.
This covers the organic certificate with the code number of the control body, fair-trade and animal-welfare marks, and a carbon footprint where you calculate one. Each piece of evidence comes with its issuing body, number and validity. That way every claim can be checked.
Downloads
The checklist for food as a PDF to print and tick off - no account needed.
The checklist for food lists duties that apply today under existing law. The EU has excluded the industry from the product passport, so no passport act will follow; we update the list when the underlying law changes.
Transpareo for food
Transpareo is the DPP software for food manufacturers who want their product data in one place. You create ingredients, allergens, nutrition values and origin as fields of their own, with a unit where there is one. Certificates and lab reports sit on the product as documents. You keep passports per product, batch or item.
Data comes in through the web interface, by Excel import or through the API. So your merchandise management system stays the source. Origin details and coordinates you let your suppliers fill in themselves. You review every value before you take it over.
You set for every field who may see it. Every publication is signed, and every reader checks the signature with the Transpareo Time Machine. Transpareo translates your details into 40 languages, and you review the result. Behind the QR code there is no advertising and no tracking in the browser. You export your data at any time as JSON-LD, CSV, Excel spreadsheet or SQL.
Frequently asked questions about the DPP for food
Is a digital product passport mandatory for food?
No. The Ecodesign Regulation excludes food and feed. No delegated act will ever cover a jar of jam. What is mandatory is everything around it. That includes the food information rules since 2014 and the wine e-label since 2023. Then come the packaging regulation since August 2026 and the Deforestation Regulation from December 2026. A passport in Transpareo brings this data together in one place. The QR code on the pack leads to your page, in the reader’s language.
What applies to wine since December 2023?
Since 8 December 2023 wine has carried an ingredient list and a nutrition declaration. On the label the nutrition declaration may be limited to the energy value. The full declaration and the ingredient list then sit behind an electronic reference, usually a QR code. The allergens stay on the label. The page behind it shows no advertising and collects no user data. The Commission Notice of 24 November 2023 spells out the details. Since March 2026 the Commission may set a common symbol for the reference. In Transpareo the page shows no advertising, and nobody tracks the reader in the browser.
May I move the ingredient list behind a QR code for other foods too?
No. Outside wine the mandatory particulars appear directly on the pack. A QR code may show additional, voluntary information. That information may not take space from the mandatory particulars. It may not mislead either. So the passport is a second surface next to the pack. What has to be printed stays printed.
Does this apply to importers?
Yes. If the operator named on the pack is established outside the EU, the importer is responsible. Under the Deforestation Regulation the importer is usually the first operator. The due diligence statement and the coordinates then rest with it. Both duties stay with it, even when a service provider collects the data. Settle the data delivery in the purchase contract, before the next harvest. With a supplier request in Transpareo, your suppliers fill in the details themselves.
Do I need a GTIN?
No rule in food law requires one. Almost every food product has one anyway, because retail asks for it. With a GTIN, Transpareo turns the identifier into a GS1 Digital Link that other systems resolve too. The same code on the pack can then serve the till and the passport. Without one, Transpareo issues a unique identifier of its own. The QR code works the same either way.
Do I need one passport per batch?
Usually yes. Nutrition values shift with the harvest, origin with the supplier. A recall always concerns particular batches. In Transpareo you publish the passport per product, batch or item. A batch keeps the product data that applied when it was created. In a recall you suspend the passports of the batches concerned. You create many batches at once through the API.
What does the Deforestation Regulation require, and from when?
It covers cattle, cocoa, coffee, oil palm, rubber, soya and wood, and the products made from them that its list names. Whoever first places them on the EU market shows that they are deforestation-free and legally produced. For that it files a due diligence statement. It includes the geolocation of all plots. The duties apply from 30 December 2026. Natural persons and micro and small enterprises follow on 30 June 2027. From 30 December 2027 soluble coffee and frozen cattle tongues join. The dates have moved twice. So read the consolidated version.
Who sees which data?
Food law knows no reading tiers like the batteries regulation. It separates what must go on the pack, what the authority may see and what you show voluntarily. In Transpareo you set for every field who may see it. Ingredients, allergens and nutrition values are visible without a login. Supplier declarations, coordinates and audit reports are seen only by the readers you admit. Coordinates of farmland are commercially sensitive. They rarely belong on a public page.
How long does the passport have to stay available?
Food law sets no period for it. In practice it runs longer than the best-before date. A consumer who scans a jar in 2029 should not meet a dead link. You keep the due diligence records for five years. Ask every provider what happens to your passports after a cancellation. With Transpareo, published passports stay reachable at a permanent address. Our provider checklist names more questions.
What does non-compliance cost?
The member states enforce the food information rules, and the fines vary widely. The Deforestation Regulation costs more. For a company the maximum fine is at least 4 per cent of its annual turnover in the EU. Confiscation of the goods and of the revenue from them comes on top. Market access often weighs more. Without a valid due diligence statement a consignment may not be placed on the market at all. For a container of cocoa that is a stopped shipment with a best-before date.
Official documents
Legal sources for food to read for yourself: what each document is and when you need it.
- Regulation (EU) No 1169/2011 on food information to consumersThe core of food labelling, applicable since 13 December 2014 and, for the nutrition declaration, since 13 December 2016. It lists the mandatory particulars and governs the allergens and the nutrition declaration. Read it when this page leaves a question open.
- Regulation (EU) 2021/2117 on the wine sectorAmends Regulation (EU) No 1308/2013. The ingredient list and the nutrition declaration become compulsory for wine, and the list as well as the full declaration may be given by electronic means. Applicable to wine labelling since 8 December 2023.
- Regulation (EU) 2026/471 (EU wine package)In force since 18 March 2026. Lets the Commission set a common symbol for the reference to the e-label. From 19 September 2027 ingredients and nutrition values are no longer required for wine intended solely for export.
- Commission Notice on the new wine labelling provisionsThe Commission’s questions and answers of 24 November 2023 on ingredient lists, nutrition declarations and electronic labelling for wine. It says what the QR code may lead to. Read it before you build a wine e-label.
- Regulation (EU) 2023/1115 on deforestation-free productsCovers cattle, cocoa, coffee, oil palm, rubber, soya and wood. It governs the prohibition, the obligations of operators and the information including the geolocation of plots. Read the consolidated version, because the dates have moved twice.
- Regulation (EU) 2025/2650 amending the Deforestation RegulationThe amendment of 19 December 2025. It simplifies the duties and sets the current dates, 30 December 2026 and 30 June 2027. Read it when you plan your supplier onboarding.
- Delegated Regulation (EU) 2026/2102Recasts the list of covered products of the Deforestation Regulation, in force since 18 September 2026. Soluble coffee and frozen cattle tongues join from 30 December 2027, and soya beans for sowing drop out.
- Regulation (EU) 2018/848 on organic production and labellingApplicable since 1 January 2022. Defines what may be called organic, how the EU organic logo is used and which code number the control body carries. The reference for any organic claim in a passport.
- Regulation (EU) 2025/40 on packaging and packaging wasteApplicable since 12 August 2026. The harmonised sorting label applies from 12 August 2028 at the earliest, the label and data carrier on reusable packaging from 12 February 2029 at the earliest. Minimum recycled content in plastic packaging applies from 1 January 2030 at the earliest.
Further reading on our blog
For most companies the first hurdle is product data spread across PDFs, emails and a dozen spreadsheets. Sorting it out is where the opportunity lies.
GS1 Digital Link is an international standard for the QR code on a product passport. What it means for interoperability.
ERP, MES, PLM and PIM feed the Digital Product Passport through Transpareo Connect yet keep control. Data flows in one direction only, and all that comes back are receipts.
How companies use the compliance passport for lead generation, without greenwashing. Every QR scan is a consumer interaction.
The QR code is on the bottle anyway
Start free and make the page behind it yours: ingredients, allergens, origin and certificates in every market language.