Reg. (EU) 2024/1781 · data carrier specified per delegated act · first working plan: textiles, furniture, mattresses, tyres + steel/aluminium intermediates.
Unlike the Battery Regulation, ESPR does not hard-code one carrier: each category's delegated act specifies the data carrier requirements for its Digital Product Passport. That makes the carrier a design decision manufacturers actually own — and the right answer depends on what the product endures, how long the passport must stay reachable, and whether a copied code costs you anything. For a €15 t-shirt and a €3,000 sofa the answer is not the same.
Fast-moving products with modest counterfeit exposure and a passport that mostly serves point-of-sale disclosure: a printed QR on the label or hangtag does the job the delegated act asks of it, at printing cost.
Products that outlive their labels — furniture, mattresses, premium apparel — or that carry resale value worth faking: chip-in-product identity keeps the passport reachable after the hangtag is gone and makes authentication part of the same tap.
| Criterion | QR / printed 2D code | NFC chip (Aeroz) |
|---|---|---|
| Named as a DPP carrier in EN 18220:2026 | Yes — QR and Data Matrix | Yes — NFC, HF RFID and RAIN UHF are named alongside them |
| Passport reachable after the label is gone | No — hangtags and sewn labels are removed or wear out | Chip lives in the product through use, washing, resale |
| Resale & second-hand market | New owner inherits a dead link | Tap re-opens the same passport; history intact |
| Anti-counterfeit value | None — codes copy perfectly | Cryptographic identity; fakes fail the tap |
| Repair & service events | Not attributable to the unit | Events append to the unit's own record |
| Unit economics | Printing cost | Cents per unit, justified where lifetime, fraud or service value exists |
The delegated acts will set minimums, not optimums. Category rules tell you what carrier is permitted; your product's lifespan, fraud exposure and service model tell you what carrier is wise. Decide on the second question — the first is table stakes.
Regulation 2024/1781 establishes that products will carry Digital Product Passports accessed via a data carrier — but delegates the specifics, category by category, to delegated acts.
Your category's act defines passport content, who holds it, and the carrier requirements. Textiles lead the first working plan; furniture, mattresses and tyres follow — watch your act, not the framework.
The harmonized DPP data-carrier standard covers Data Matrix, QR, HF RFID, NFC and RAIN UHF RFID — and requires that consumers reach DPP information with no app, no registration, and decoding native to the smartphone OS. An NFC tap returning a URL meets that rule natively.
The companion identifier standard requires that the unique product identifier be retrievable from a data carrier specified in EN 18220, that it be a URL or derivable into one — and that if a product's identification granularity ever changes, the new identifier be linked to the old one to maintain traceability.
The framework regulation does not name one carrier for all products — each category's delegated act specifies carrier requirements. Printed 2D codes are the expected baseline; more durable machine-readable carriers fit the same resolver architecture.
Yes — EN 18220:2026, the harmonized DPP data-carrier standard, names NFC and RAIN RFID as DPP data carriers alongside QR and Data Matrix, and rates NFC's native smartphone support as pervasive. Each category's delegated act chooses from that menu; where it requires a printed code, the chip complements rather than replaces it.
The first ESPR working plan prioritises textiles, furniture, mattresses and tyres, plus iron/steel and aluminium intermediates. Textiles' delegated act will set the template the others follow.
EN 18219:2026 Annex A gives the test: item-level identification is advisable where a product is used after sale, repaired or refurbished, upgradeable, subject to maintenance or statutory audit, has usage data worth recording, or is exposed to a high risk of counterfeiting. Score each SKU against that list — high on any line argues for chip identity; low on all of them and the printed code is the rational choice.
A fixed-fee Aeroz audit maps your products, line speed and regulation against both carriers and returns a written recommendation with a scoped pilot plan, cost and timeline. $5,000 books it online; no commitment to proceed.