Digital Product Passport for food

No. Art. 1(2)(a) and (b) of the Ecodesign for Sustainable Products Regulation exclude food and feed as defined in Regulation (EC) No 178/2002, so no ESPR delegated act will ever cover a jar of jam. What is mandatory is everything around it - the food information rules since 2014, the wine e-label since December 2023, the EUDR from December 2026 and the packaging regulation since August 2026. A passport is where you put those obligations so they stop living in four systems. And it pays for itself before any law asks for it - the QR code on the bottle becomes your page in every market language, and a recipe change is corrected online the same day.

Wine has carried a compulsory ingredient list and a compulsory nutrition declaration since 8 December 2023, under Regulation (EU) No 1308/2013 as amended by Regulation (EU) 2021/2117. Both may be given by electronic means. The energy value has to stay on the physical label, and the allergens have to stay on it too. The page behind the QR code may contain no advertising or sales content, and it may not collect or track user data. The Commission Notice of 24 November 2023 spells out the details.

No. Outside wine, Regulation (EU) No 1169/2011 still requires the mandatory particulars on the pack itself. A QR code may carry additional voluntary information, and it may not present it in a way that displaces or contradicts the mandatory particulars. So treat the passport as the second surface, not as a replacement, and print what has to be printed.

Yes. Under Art. 8(1) of Regulation (EU) No 1169/2011 the importer into the Union market carries responsibility for the food information whenever the operator named on the pack is not established in the Union. Under the EUDR the importer is normally the operator that places the commodity on the market, which means the due diligence and the plot coordinates land with it. Neither duty can be delegated by contract, though the data collection obviously can - and should be agreed before the season starts.

No rule in food law requires one, but almost every food product already has one because retail asks for it. If you have a GTIN, the identifier in Transpareo becomes a GS1 Digital Link that other systems resolve too, so the same code on the pack can serve the till and the passport. Without one the product gets a unique Transpareo identifier and the QR code works just the same.

Usually yes, and that is the real difference from durable goods. Nutritional values shift with the harvest, origin shifts with the supplier, and a recall is only ever about specific batches. Transpareo supports batch-level and item-level passports through serial identifiers, so the model data stays in one place while the batch carries what actually varies. Publishing thousands of batches by hand is not the plan - that is what the Excel import and the API are for.

For cattle, cocoa, coffee, oil palm, rubber, soya and wood, the operator that places the product on the market has to show it is deforestation-free and legally produced, and file a due diligence statement (Art. 3, Art. 4, Art. 8). The information duties include the geolocation of every plot of production, as polygons for plots above four hectares for every commodity except cattle (Art. 9 and Art. 2(28)). The duties apply from 30 December 2026, and from 30 June 2027 for natural persons and micro and small enterprises established as such by 31 December 2024. The dates were set by Regulation (EU) 2025/2650 after two postponements, so check the consolidated text rather than an old briefing.

Food law does not grade information into tiers the way the batteries regulation does. What it does is separate what must be on the pack, what must be available to the authority and what you disclose voluntarily. In Transpareo, visibility is a property of every data field, so the ingredient list, allergens and nutrition appear without any login, while supplier declarations, plot coordinates and audit reports sit behind logged access for the people entitled to them. Plot coordinates in particular are commercially sensitive and rarely belong on a public page.

There is no single retention period in food law, but the practical answer is longer than the shelf life. A consumer who scans a jar in 2029 should not meet a dead link, and a due diligence statement has to be retrievable for years after the shipment. So ask any provider what happens to your passports after a cancellation - with Transpareo, published passports stay reachable through a permanent address, and our provider checklist names the further questions worth asking.

Food information breaches are enforced by the member states, and the fines vary. The EUDR is the expensive one - Art. 25 requires fines proportionate to the environmental damage and to the value of the goods, with a maximum of at least 4 per cent of the operator’s annual Union-wide turnover, plus confiscation of the products and the revenue from them. Worse than the fine is the market access - a consignment without a valid due diligence statement may not be placed on the market at all. For a container of cocoa that is a stopped shipment with a shelf life attached to it.