must someone also be able to view the product passport without internet connection

What you must concretely do

What is expected of you

The ESPR governs how a digital product passport must work, but an explicit obligation that the passport must also be accessible without an internet connection does not appear as such in the text. What there is, however, are a number of technical requirements that determine how accessible and how robust the passport must be — and from these it can be inferred what is expected in practice from a provider such as alupas.eu and from a manufacturer.

Access via the data carrier, not via a separate file

Article 11 of the ESPR (Regulation (EU) 2024/1781) describes the technical design and functioning of the digital product passport. The passport is unlocked via a data carrier on the product — in practice a QR code. That code points to data that is held online; the passport itself is not a file that you download and take with you. For a company of 10 to 100 employees, this means that the question "offline or online" actually shifts to a different question: is the data carrier on the product itself always readable, even without an internet connection being available at the time to the person scanning? How that carrier comes to be placed on the aluminium and remains in place is described on How does the QR code for the digital product passport get onto my aluminium?.

Availability of data, not of the connection

Article 10 of the ESPR (Regulation (EU) 2024/1781) sets requirements for the product passport itself: what data it must contain and how that data must be accessible to different user groups — consumers, economic operators, supervisory authorities. These requirements concern the content and accessibility of the data at the time someone consults it, not the question of whether a user must be able to keep a local copy in case there is no network. For a production company, this means that attention should be focused primarily on the question of whether the correct data is unlocked at the right time, not on building an offline copy of the passport.

Uniqueness of identification remains necessary, connection or not

Article 12 of the ESPR (Regulation (EU) 2024/1781) requires a unique identification code per product. This code is the key by which a passport is found, and that code is physically on the product — even if there is no connection, the code itself is readable or scannable. What is then still missing in the absence of internet is the link to the underlying data. How such a code is assigned and managed is explained on How do I give each product a unique identification code?.

Findability via the register

Article 13 of the ESPR (Regulation (EU) 2024/1781) governs the register of digital product passports. This register is an online facility in which (part of) the passport data is entered so that supervision and control can take place centrally. This register is also by definition an online system; the regulation does not describe any offline equivalent. What exactly ends up in that register and who has access to it is addressed on What is the registry of digital product passports and what do I need to enter into it?.

Where things go wrong in practice

A number of situations recur in practice at aluminium-processing companies when it comes to passport accessibility.

At a production location with limited or shielded wifi, an employee or inspector can scan the QR code, but does not establish a connection to the underlying data. This is often incorrectly interpreted as an error in the passport itself, whereas it is a local network issue.

When exporting to locations with variable connectivity — a storage facility at a port, a shipyard without a fixed network — a customer sometimes expects the passport to be "simply" accessible like a PDF stored locally. That is a different usage model than what the data carrier offers.

A third situation: a profile manufacturer copies the passport data to a separate PDF file "in case the website goes down" and distributes that file. Such a copy may contain outdated or incorrect data once the passport is amended after publication — see also how do I update data in a product passport that is already published — so that two versions of the truth exist side by side.

A fourth situation arises when the QR code on the aluminium itself becomes damaged or unreadable through transport, coating or wear. In that case it is not a question of an offline problem, but of a physical problem with the carrier; that scenario is described on what happens if the QR code on my aluminium becomes illegible.

Finally: a foundry that links the passport to its own ERP system sometimes assumes that internal system access is equivalent to compliance with external accessibility requirements. Both things go hand in hand, but they are not identical — see Can I link the digital product passport to my ERP or inventory system? for how that coupling works properly while keeping external accessibility in view.

What you can document now

• An overview of the locations and circumstances in which the aluminium and the associated QR code are physically scanned, including known network limitations at those locations.
• Agreements with customers about what they expect in terms of passport accessibility at their own location, before a delivery takes place.
• A procedure for the event that the data carrier is damaged, including who within the company is responsible for repair or replacement.
• An internal agreement about whether or not to distribute local copies of passport data, and if so, how to prevent an outdated copy from remaining in circulation.
• Documentation of the chosen technical setup of the data carrier and the link to the underlying data, so that if a customer or supervisor has questions, it is clear how access to the passport is technically arranged.