can I register multiple products at once for a product passport

What you must concretely do

What is expected of you

The ESPR speaks of the product passport per product or per product group, but leaves room for a practical implementation of how that passport is created. For a company that places aluminium profiles, castings or packaging material on the market, this means that the question "can I submit multiple products at once" is primarily a question about how the passport is compiled and linked to the data carrier — not about whether that is permitted.

One passport per product, based on shared data

Article 9 of the ESPR (Regulation (EU) 2024/1781) links the digital product passport to the product or product model. For a company with 10 to 100 employees, this means in practice that a series of profiles with the same alloy, the same dimensions and the same manufacturing route share the same underlying data in essence. The submission of that data — composition, origin, recycling percentage — can be done in bulk; the passport itself, however, remains linked to the specific product or product group for which it was drawn up.

Structured data that is machine-readable

Article 10 of the ESPR (Regulation (EU) 2024/1781) sets requirements for the format and structure of the data in the passport. For practical purposes, this means that a submission of multiple products at the same time only works if the underlying data are clearly and consistently organized — the same fields, the same units, the same coding per product variant. A spreadsheet with different completion conventions per product line requires more research work in a joint submission than it saves time.

Registration in the central register

Article 13 of the ESPR (Regulation (EU) 2024/1781) regulates the register in which each passport is entered with a unique identification. In practical terms, this means that even with a joint submission of multiple products, each passport ends up separately in that register and receives its own identification. A batch submission is thus a matter of efficient input at the front end; at the back end, each product retains its own passport with its own searchable status.

Access via the web portal

Article 14 of the ESPR (Regulation (EU) 2024/1781) describes the web portal through which data from the product passport are made accessible to parties entitled to access it, such as supervisory authorities. For a company that registers ten or twenty product variants in one batch, this means that each variant must be individually searchable and retrievable via that portal — the joint submission at the front end does not change the requirement that each product passport is complete and findable in its own right.

Where things go wrong in practice

At an aluminium foundry that supplies ten variants of the same casting, sometimes a single data set is completed and simply copied to the other nine product passports. A difference in alloy composition or in post-processing between those variants then goes unnoticed in the product passports, even though it is a real difference in the product.

At a profile manufacturer that registers multiple length sizes of the same profile, confusion sometimes arises about whether this is one product passport with variants, or multiple separate product passports. That choice has consequences for how the QR code on the product is linked — an incorrect link means that a scan on one profile shows the data of another.

With packaging aluminium where the same foil is supplied in different roll widths, the registration of multiple products at once is sometimes done by an importer who does not have all the underlying production data. The bulk registration then proceeds faster than the question of whether the manufacturer or importer has actually supplied the correct data per variant, as described on What does an enforcement authority ask for during an inspection on aluminium?.

It also happens that a company thinks that a joint registration automatically means a joint product passport — with the result that in a later modification of one product, the data of other products are inadvertently overwritten, because the underlying files were not strictly separated per product variant.

Finally, it goes wrong when multiple products are registered at the same time without clarity on who within the company is responsible for maintaining the source data per variant — with the result that nobody notices when a specification of one variant changes.

What you can document now

• An overview per product line or product group of which characteristics are shared (alloy, origin, general production data) and which characteristics differ per variant (size, weight, specific post-processing).
• A fixed template structure for data submission, so that a joint registration of multiple products does not result in inconsistent fields or units.
• An indication of who within the company is responsible for keeping the source data per variant current, also after a joint registration.
• A test phase in which a small number of products is first registered before a complete product line is processed in bulk — this can take place before the obligation comes into force, as described on can I test a product passport now before it becomes mandatory.
• An internal explanation for the people carrying out the submission, on the difference between a shared data source and a separate product passport per product, so that a later modification does not inadvertently affect multiple product passports — useful in preparing colleagues as discussed on how do I explain to my colleagues what changes with the product passport.
• A step-by-step plan for the submission itself, with a fixed sequence of data collection, verification and submission, as detailed on How do I tackle the product passport for aluminium step by step?.