The Ecodesign for Sustainable Products Regulation (ESPR) does not give one list of fields for every product. Annex III sets out the classes of data a passport can hold. Each product group's delegated act then says which classes apply, and how the data is laid out, carried and kept available. Under Article 9(2), the act also sets who may create or update the passport, and how long it stays available, which must be at least the expected lifetime of the product.
The data classes in Annex III
The classes are:
- The ecodesign information that Article 7 requires.
- A unique product identifier.
- The global trade item number.
- Commodity codes, such as the customs tariff code (TARIC) for imports.
- Compliance documentation, such as the declaration of conformity and technical documentation.
- User manuals, warnings and safety information.
- The manufacturer's identifier and the unique operator identifier.
- The unique facility identifier.
- Importer details, including the EORI number.
- A contact for the EU responsible operator.
- A reference to the backup service provider.
- Optional ecodesign information and labels.
Model, batch or item
A passport can refer to a product model, a batch or an individual item. Article 10(1)(f) says the data shall refer to whichever of those the delegated act specifies. Article 9(2) makes that choice part of each delegated act.
No product delegated act is adopted yet, so no product group has that rule in force. Until one is, plan for the level your product group is likely to use, and check it when the act is published.
Standards for the data
The Regulation also sets rules on how the data is kept. Article 9(1) says it must be accurate, complete and up to date. Article 10(1)(d) says it must be open, interoperable and machine-readable, with no vendor lock-in. Article 10(1)(e) says customer personal data is not stored without explicit consent.
What a draft for steel looks like
The Commission's Joint Research Centre published a draft proposal on steel passport content in spring 2026. It is a draft for stakeholder consultation, not an act. It shows the kind of fields being considered, including a unique product identifier, the product name and model, the manufacturing site, and whether substances of concern are present. Use it as a guide to what a steel passport might hold, not as a list of what is required.
How TraceID holds this data
Traced holds a product record with its image, certificates and manuals. Batches sit beneath it, each with an operator, a start and an end, a PASS or FAIL result, and quality data such as CMM results.
A passport in Traced is any JSON the customer uploads. It is versioned, carries a SHA-256 checksum, and keeps every earlier version. Each serialised product, or each batch, gets a 16-character trace ID, shown as a QR code. Anyone can open the public scan page, and the same URL returns the passport as JSON. Signed-in staff also see the batch record. Every scan is logged.
Traced does not yet check a passport's fields against the regulation, because the rules for iron, steel and aluminium are still being finalised. We will adopt the iron and steel and aluminium delegated-act schemas as they are published.
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