Can a Digital Product Passport Replace Labels, Manuals or CE Marking?

A Digital Product Passport does not automatically replace physical labels, safety instructions or CE marking. See what can move digital and what still has to remain.

Last verified: 3 September 2026

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Overview
Direct answer
The DPP is a publication surface, not an override
CE marking stays a separate legal act
Manuals are more nuanced
A required label can still be a required label
A DPP can contain something without legally replacing it
What should a business digitise first?
What this means for ecommerce teams
Direct questions
What would change this page
Try it on one product
Primary and official sources
Keep exploring

A Digital Product Passport can move some product information into a governed digital record. It does not create a general right to remove labels, safety information, instructions or CE marking from the physical product. The rule that requires the information still decides where it has to appear.

Direct answer

No, not as a general rule.

The Digital Product Passport is another legally recognised place where product information can live. It is not a blanket replacement for every physical label, mark, instruction sheet or compliance document already required by EU law.

The Ecodesign for Sustainable Products Regulation, ESPR, is unusually clear on this point. Article 7 says that where a DPP is available, required information is provided in it and, where necessary, may also have to be provided on the product, packaging, a label, a user manual or another accompanying document.

That gives businesses a useful rule:

Information being available in the DPP does not, by itself, mean the same information may disappear from everywhere else.

The law that creates the information requirement still decides the publication surface.

That matters because four things that look similar in a compliance project are legally different:

Thing	What the DPP can do	What the DPP does not automatically do
Product label	Carry some or all of the same underlying product information	Cancel a label requirement in another rule
User instructions	Hold digital instructions and make them accessible through the product carrier where ESPR applies	Remove every paper instruction or safety statement
CE marking	Carry conformity information around the product	Replace the CE mark where CE marking is required
Compliance documents	Link to or contain documents where the applicable product rule allows it	Turn the passport into a universal substitute for technical documentation or declarations

The practical question is therefore not “Can this fact go in the DPP?”

It is:

“Which law requires this fact, and where does that law say it must be available?”

For the wider distinction between mandatory, conditional and voluntary passport information, use DPP Data Requirements: Mandatory, Conditional and Voluntary Information.

The DPP is a publication surface, not an override

Article 7(7) of ESPR is the starting point.

Where a DPP exists, required information is provided in the DPP. But the same paragraph says that, where necessary, the information is also provided in one or more additional forms:

on the product itself
on the product packaging
on a label
in a user manual or other documentation accompanying the product
on a free-access website or application.

That is not duplication by accident. The Regulation deliberately allows the Commission to choose different publication surfaces for different kinds of information when it writes the product-specific delegated act.

A product may therefore end up with:

one governed fact, several legal presentation surfaces.

That is a better data architecture than maintaining a separate value for the DPP, the label, the product page and the manual.

The canonical product fact should be governed once. The publication rule then decides where that fact is rendered.

This is one reason which system should own each product fact matters before a business starts designing a passport.

CE marking stays a separate legal act

A DPP does not replace CE marking where CE marking applies.

ESPR itself keeps the two duties separate.

Article 46 says the CE marking is to be affixed visibly, legibly and indelibly to the product. Where that is not possible or not warranted because of the nature of the product, it is affixed to the packaging and accompanying documents.

The same Regulation separately requires a DPP where the applicable delegated act makes one mandatory.

So a covered product can need both:

CE marking + Digital Product Passport

rather than one or the other.

This distinction is also visible in the duties ESPR places on importers and distributors. An importer must check, where applicable, that the product bears the required CE marking and that a DPP is available. A distributor likewise checks the required conformity marking and, where relevant, that the product is labelled or linked to the DPP.

That is strong evidence against treating the passport as a replacement conformity mark.

There is another important boundary. Not every product carries a CE mark. CE marking only applies where the relevant EU harmonisation legislation requires it. A DPP should therefore never be described as “the new CE mark”. It is not.

For the broader question of what a DPP proves and what it does not, see Who Checks Digital Product Passport Information?.

Manuals are more nuanced

Manuals are the area where the DPP can genuinely reduce paper, but the answer is still not “everything becomes digital”.

ESPR Article 27 requires manufacturers of products covered by an ESPR delegated act to provide digital instructions in a language that can be easily understood as determined by the Member State concerned.

Where a DPP applies, those digital instructions are included in the passport and made accessible through the corresponding data carrier.

That is a real digitalisation route.

But ESPR immediately places limits around it.

Manufacturers must still provide, in paper and in a concise format:

safety information
instructions relevant to the health and safety of customers and other relevant actors.

The customer can also request the digital instructions in paper form at the time of purchase or for up to six months afterwards, and the manufacturer must provide them free of charge within the period set by the Regulation.

A product-specific delegated act can additionally require parts of the digital instructions to be provided on paper.

So the useful summary is:

ESPR allows a large part of the instruction set to become digital. It does not make physical safety information disappear.

For a business building a DPP, that means the instruction record should be structured so the same governed source can support:

the DPP
any downloadable manual
required paper safety information
other sales or service channels.

It should not be copied into four independent documents and maintained four times.

A required label can still be a required label

ESPR also contains its own label mechanism.

Where an ESPR delegated act requires a label under Article 16, Article 32 requires the economic operator placing the product on the market to ensure each individual unit is accompanied by the printed label required by that act.

The Commission can require that label to contain a data carrier or another route to additional information, including the DPP.

That relationship is important:

the label can point to the passport

without

the passport replacing the label.

The same principle applies when another piece of product law already requires labelling.

For example, a textile fibre-composition obligation should not be removed merely because the composition can also appear in a future textile DPP. The specific textile rule and the future textile delegated act must be read together. The current field-level position is maintained on Fibre Composition.

Likewise, safety warnings required by product-specific law do not become optional merely because a DPP can display them. The toy example is worked through in Are Toy Safety Warnings Mandatory in the Toy Digital Product Passport?.

A DPP can contain something without legally replacing it

This is the easiest mistake to make when reading Annex III of ESPR.

Annex III describes information that a DPP may contain or link to, including compliance documentation and other product information required by Union law.

That tells you what the digital record can support.

It does not say that every document included in or linked from the DPP may be withdrawn from every other legally required location.

The same distinction appears elsewhere in the estate.

A detergent DPP does not automatically replace a REACH Safety Data Sheet. The detergent DPP and SDS answer is here.

A DPP does not automatically replace a SCIP notification. The DPP vs SCIP boundary is here.

And where EPREL applies, the DPP does not simply make the existing energy-labelling register vanish. See DPP vs EPREL.

These are all versions of the same rule:

A new digital destination does not repeal an older legal obligation unless the legislation actually says it does.

What should a business digitise first?

The low-regret approach is to separate the fact from the surface.

For each piece of regulated product information, record:

the canonical value
the product, variant, batch or item it applies to
the evidence behind it
the rule that requires it
the markets in which that rule applies
the surfaces on which it must appear
the language or presentation requirements
the date from which the current version applies.

Then the same fact can be published consistently to the places that need it.

A simple internal model might look like:

Governed fact	DPP	Physical product	Packaging	Label	Manual	Online offer
Product identity	Yes, if required	Depends on rule	Depends	Depends	Sometimes	Often
Fibre composition	Future DPP position product-specific	Existing textile law may require marking/labelling	Product-specific	Product-specific	No general rule	May be commercially shown
Safety warning	Can be included where applicable	Often legally required	Often legally required	Product-specific	May be required	GPSR/sector law may require online display
CE marking	DPP may contain related conformity information	Yes where CE applies	Only where product affixing is not possible/warranted	Not a DPP substitute	Accompanying docs in fallback case	Not a substitute for affixing
Digital instructions	Yes where ESPR requires	Access route via carrier	Possible access route where no DPP	Product-specific	Digital, with paper safety core and paper-on-request rules	Can be linked

The exact answer changes by product rule, but the operating model does not.

If you are still deciding what is law and what is preparation, start with What a delegated act will actually decide about your products.

What this means for ecommerce teams

A DPP does not reduce the job to “put everything behind a QR code”.

An ecommerce team may still have to publish information directly on the product page because another rule requires it there, while also providing access to the DPP.

The clearest current example is GPSR Article 19. It requires specified manufacturer, responsible-person, product-identification and applicable safety information to be clearly and visibly indicated in an online offer. A link to a DPP should not be assumed to replace those online-offer fields.

That question is owned by What Product Information Must an EU Online Listing Show Under the GPSR?.

The separate question of where the DPP itself needs to be accessible online is covered in Where Does a Digital Product Passport Have to Appear on an Ecommerce Product Page?.

Direct questions

Can I remove the CE mark if the DPP contains a declaration of conformity?

No. Where CE marking is required, the CE-marking rules continue to apply. ESPR itself requires the CE marking to be affixed and separately requires the DPP where a delegated act makes one applicable.

Can the DPP replace a paper user manual?

Sometimes part of the instruction set can become digital under ESPR, but not every physical information duty disappears. ESPR retains concise paper safety information, allows customers to request the digital instructions on paper and lets delegated acts require additional information in paper form.

If information is already in the DPP, do I need to repeat it on the label?

Possibly. Article 7 expressly allows information to be required in the DPP and, where necessary, on another surface. The applicable product rule decides.

Can I put the CE mark inside the QR code instead of on the product?

Not under the general CE-marking rule. Where CE marking applies, Article 46 ESPR requires physical affixing to the product, with the packaging/accompanying-document fallback where physical affixing is not possible or not warranted.

Does a DPP replace existing sector rules?

No, not automatically. ESPR is designed to operate alongside other Union product legislation, and product-specific DPP rules have to be read with the existing legal requirements for that product.

What would change this page

Recheck this page when:

a product-specific ESPR delegated act expressly changes where information must appear
sector legislation is amended to allow a digital substitute for a current physical requirement
the Commission changes the horizontal rules for digital instructions
a product-specific rule changes its CE-marking, labelling or documentation requirements.

A change for one product group should not be generalised to every DPP.

Try it on one product

A useful first step is not deciding what to print. It is establishing which product facts you already hold, what supports them and which publication surfaces may need the same governed value.

Activate one product →

Keep exploring

The questions this page usually raises next.

Does this reach your products?

Give ActivateDigital one product and it works out which obligations apply from the product's own character, and says which it cannot decide.

Check a product How a value is decided

Help someone else make sense of product passports.

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Primary and official sources

https://single-market-economy.ec.europa.eu/single-market/goods/ce-marking_en Used only as supporting Commission guidance. The legal rule above is primary.

Last verified: 3 September 2026. This page is practical guidance, not personalised legal advice.