A Digital Product Passport is a record. RFID, NFC and a printed QR code are carriers, which is to say the thing on the product that takes a person or a system to that record. The passport is what you are obliged to produce. The carrier is mostly your choice, and that choice decides what the passport can do once compliance has been dealt with.
Most people meet the two as one idea and go shopping for a tag first. That is the wrong order, and it is an expensive one.
The record and the carrier are two different projects
The record is a structured data set about a specific product, batch or item: what it is made of, where it came from, its carbon footprint, how to repair and recycle it, who is legally responsible for it. Assembling that is a procurement and data problem and it takes months, because most of the information sits with your suppliers rather than with you.
The carrier is a piece of print or hardware that resolves to the record. Specifying it takes an afternoon. Changing it later means a new run of labels or tags, which is irritating but survivable.
Keep them apart in your planning. A brand with verified product data and a plain printed code is compliant. A brand with beautiful tags and no supplier data is not.
What the regulation actually asks for
Check the detail. Everything here about regulatory expectations comes from our research in March 2026, and the delegated acts are still arriving. Verify against the official timetable and the text for your own category before you plan around any of it.
The Ecodesign for Sustainable Products Regulation expects a passport to be reachable from the product itself through a data carrier. In the guidance and the early category work, the carrier described is normally a printed code: a QR code or a data matrix.
Nothing in it obliges you to use radio. If your only goal is to satisfy the requirement in your category, print a durable code, point it at a record you keep accurate, and you are finished.
We say that plainly because it costs us work. A great many passport programmes do not need RFID, and a supplier who tells you otherwise is selling hardware rather than answering your question.
The three carriers, and what each one buys
| Carrier | Read with | Range | What it unlocks |
|---|---|---|---|
| Printed QR or data matrix | Any phone camera | Line of sight, has to be found and aimed at | Consumer access to the passport at the lowest possible cost, on anything printable |
| NFC tag (HF) | Any modern phone, no app | Touching distance | A tap with no aiming, a tag that survives wear and wet, chip features print cannot have |
| UHF RFID tag | A dedicated reader | Metres, hundreds of items at once | Reading items in bulk, inside cases and on pallets, with nobody looking at them |
Where a printed code stops
A printed code is a link, and it is the same link on every copy of that label. It can be photographed and reprinted, and every copy scans identically. It can tell you what an item claims to be. It cannot tell you that the claim is true, or that this is the individual item the code was printed for.
That is perfectly adequate for compliance information, which is a statement about a product rather than a proof about an object. It is not adequate as the foundation for authenticity, ownership or anything that has to be true of one specific item.
Where NFC earns its cost
NFC changes the interaction more than the data. Tapping is a different behaviour from scanning: no aiming, no app, no hunting for a code on a wet or worn label. The tag can sit inside the product or the closure rather than on packaging that gets thrown away, which matters if the passport is meant to outlive the first sale.
It also puts a chip in the loop. Chips can hold protected memory and support cryptographic functions that print physically cannot, and that is the technical basis on which tag authentication is built. Whether a particular programme has that running in production is a separate question from whether the silicon supports it. Ask suppliers to be precise about which they mean, ourselves included.
Where UHF earns its cost
UHF is the only one of the three that reads things nobody is looking at.
A reader at a doorway picks up every tagged item that passes through it in a second or two, inside a sealed case, with no line of sight and no human involvement. That is the technology underneath our team’s earlier work tracking more than 900 million refillable containers around a circular supply chain, and it is what makes a passport useful to operations rather than only to consumers.
If your passport is supposed to record things that happen in a warehouse, at a goods-in door, in an industrial laundry or at a recycling gate, UHF is how those events get captured without anyone scanning items one at a time. Without it, the record only updates when a person decides to update it, which in practice means it stops updating.
The honest division of labour
- Compliance is the record. The carrier can be print.
- The consumer moment is NFC, or print where the situation allows someone to aim a camera at a label.
- Operational events are UHF.
- Authenticity is a property of the chip and the system around it, not of the passport.
Choosing a richer carrier is a commercial decision. It should be justified by something you intend to do with it, not by a regulation that has not asked for it.
Both carriers on one item is normal now
Retailers increasingly want UHF for stock accuracy and loss prevention and HF or NFC for the customer standing at the shelf, and dual frequency tags exist precisely because those are two different jobs with two different readers. It is not a compromise or a hedge. It is one item answering two populations.
The decision that is not reversible
The carrier is a late decision and a cheap one to revisit. The identifier underneath it is neither.
Deciding whether an identity belongs to a model, a batch or an individual item shapes everything that comes after. Model level is the cheapest and satisfies a good deal of compliance. Item level is the only one that supports a repair history, a refill count, resale provenance or a warranty that belongs to the object rather than to a receipt. Brands that pick the cheapest level and then want any of those things within five years end up rebuilding.
Where to start
Three questions, in this order.
- What data do you actually have? If you cannot state what one product is made of, by percentage weight, with evidence, the carrier is not your problem yet.
- Who needs to read it, and where are they standing? A consumer holding the product, a warehouse operative who never touches it, and a recycler with a pile of mixed material are three different answers.
- Will the passport ever record something that happens after the product leaves you? If yes, you need a carrier that can be read without a volunteer.
Veribli builds product passports on top of tagging technology that has tracked physical items through circular supply chains for nearly thirty years, across print, NFC and UHF. If you want a straight answer about which carrier your category actually needs, call us on 01482 455 855.