what must I do if the QR code on a piece of furniture becomes unreadable

What you concretely have to do

A QR code on a piece of furniture faces removals, cleaning products, sunlight, scratches and sometimes a sanding machine. The question of what then happens to the product passport is therefore not a theoretical issue, but something that every manufacturer or importer working with carriers will sooner or later have to deal with. The ESPR itself does not literally regulate "what if the code gets damaged" — the regulation does govern what is expected of the data carrier and the passport behind it, and from this it can be inferred where responsibility lies.

What is expected of you

The data carrier must remain readable and functional throughout the entire lifetime

Article 11 of the ESPR (Regulation (EU) 2024/1781) describes requirements for the technical design and operation of the digital product passport, including the data carrier that refers to the passport. The thinking behind this requirement is that a passport that can no longer be retrieved does not exist in practice — for a user, a repairer or a supervisory authority it makes little difference whether the passport does not exist or is simply not accessible. For a company of 10 to 100 employees, this practically means that the choice of material, placement and printing technique of the QR code is part of the product design process, not a sticker that is applied afterwards. When determining how that code comes onto the product, consideration is given to, among other things, how does the QR code for the product passport get onto my furniture — a choice that is directly linked to how vulnerable the code is to damage.

The passport itself must continue to exist, separate from the physical code

Article 10 of the ESPR sets requirements for the digital product passport as such — the data must remain accessible, even if the physical carrier on the product no longer works. This is an important distinction: the QR code is the entry point, not the passport itself. For a company, this means that in addition to the physical code, there must also be another way to access the passport, for example via a unique identification code that, separately from the sticker, can be traced back to the correct product. How that looks in practice depends on the way in which each product receives a unique identification code is assigned.

The passport must remain discoverable via the register

Article 13 of the ESPR describes the register of digital product passports. A registered passport remains findable there, even when the QR code on a specific product instance no longer works. That register is thus a second layer — alongside the physical carrier on the product — through which a passport can be retrieved. What is precisely recorded and maintained in it is described under what is the register of digital product passports and what must I enter in it.

Replacing or reworking a label is subject to other rules

Articles 16 and 17 of the ESPR deal with labels and with counterfeit labels. When a data carrier is replaced — for example by a new sticker on a returned or repaired piece of furniture — it is relevant that this replacement does not give the impression of a different, potentially misleading label. For a company that performs repairs or replacements of data carriers, this means that replacing a code is a deliberate action, with a clear link to the existing passport, not a new or modified version without that link.

Where things go wrong in practice

A few situations come up regularly in practice:

• A QR sticker has been applied to a surface that is regularly cleaned with harsh chemicals, causing the code to become unreadable within a few months.
• A piece of furniture is sawn or finished to size after production, and the data carrier disappears in the process without anyone noticing this before delivery.
• When repairing or reusing, a new sticker is applied, but no one has recorded which passport goes with it, causing the link between product and passport to be lost.
• An importer assumes that the manufacturer has already applied a durable carrier, while this is not the case for the chosen material or placement.
• A piece of furniture consists of several assembled components, and it is not predetermined which component carries the data carrier — with the result that after disassembly no one knows which code belongs to which passport. This is particularly relevant for questions such as does each part get its own passport or the piece of furniture as a whole.

What you can put in order now

To demonstrably show that the data carrier and the passport have been carefully set up, it is worthwhile to document a number of things in writing:

• The choice of material, technique and placement of the QR code, with an explanation of why this choice is suitable for the intended use and environment of the piece of furniture.
• The unique identification code per product and the way in which that code remains traceable to the passport, even without a functioning physical carrier.
• A procedure for replacing a data carrier during repair, return or reuse, including who performs this and how the link with the existing passport is maintained.
• The registration of the passport in the European register, so that the passport remains findable even without a functioning QR code.
• Agreements with suppliers or importers about who is responsible for applying and maintaining the data carrier, especially when a product is further processed or assembled after production.
• Documentation on how the passport can be updated after publication, for situations where data must be corrected retroactively — see can I modify data after the product passport has already been published.

These records are not only useful as evidence to a supervisory authority, but also practical: they ensure that a damaged QR code becomes a routine matter instead of a search for what was once recorded.