What Happens to My Product’s Compliance if the QR Code Is Damaged or the Server Hosting the Data Is Shut Down After Five Years?
This is a practical Digital Product Passport question — the kind asked by those thinking in operational terms. And it deserves an equally practical answer: no, product compliance is not automatically lost if the system is properly designed. But “properly designed” is not a technical detail to leave to a software provider — it is an explicit regulatory requirement under the ESPR Regulation that anyone implementing a DPP must understand and verify.
The QR Code Is Not the DPP — and That’s the Starting Point
As we’ve already seen, the QR code — or any other data carrier — is not the Digital Product passport itself: it is the physical-digital bridge that provides access to the DPP information system. If that bridge is damaged, it is a physical issue that can be resolved by replacing the label, not a loss of data. The DPP information resides in a separate digital traceability system, not in the QR code itself.
That said, a damaged QR code on a product in circulation does create a practical product traceability and accessibility issue. For this reason, the Regulation requires that the data carrier be physically present on the product, its packaging, or accompanying documentation, while allowing flexibility in choosing the most suitable technology based on expected lifespan and usage conditions.
An NFC tag embedded in an industrial product designed to last twenty years requires very different durability standards compared to an adhesive QR label on a kitchen appliance.
The Real Issue: What Happens to the Data Over Time
The more critical question is not the physical QR code, but the persistence of the information system hosting the data. This is where many current digital traceability implementations show weaknesses — and where the ESPR Regulation sets very specific long-term requirements.
Article 11 of the Regulation explicitly states that the DPP must remain accessible and available even in the event of insolvency of the economic operator responsible for its creation, or in the case of liquidation or cessation of activity within the Union.
In simple terms: if the company shuts down, restructures, changes software providers, or disappears entirely, the Digital Product Passport cannot disappear with it. This is not a recommendation — it is a legal obligation embedded into the regulatory architecture of the DPP framework.
How This Is Ensured in Practice
This long-term Digital Product Passport persistence is achieved through two complementary mechanisms.
The first is mandatory backup: the ESPR Regulation requires that, at the moment a product is placed on the market, a copy of the DPP data must be made available through a third-party service provider — acting as an independent custodian of the data, separate from the commercial operator.
The second mechanism is the “resolution system” — a technical concept that is essential to understanding how a DPP can remain functional, accessible, and interoperable for decades.
Imagine printing a QR code on a product today. That code contains a unique product identifier registered in a central, independent registry system. When someone scans the code ten years later, the system does not directly search for the data on a fixed server: it first queries this registry infrastructure, which knows where the DPP data is currently located and redirects the request accordingly.
It works like a postal forwarding service: even if the post office changes location, letters still arrive because the system knows where to send them.
This decoupling between the physical code and the location of the data is fundamental. It means that even if, over time, the DPP technology provider changes, the infrastructure is migrated to new servers, or the company is acquired, the QR code on the product continues to function without modification.
The physical code is stable and permanent; the data location can change — as long as the registry is kept up to date.
Who Ensures These DPP Requirements — and How
These guarantees apply to anyone issuing a DPP — including companies that choose to manage the infrastructure internally.
Companies that build their own DPP systems do not bypass ESPR regulatory requirements: they effectively become DPP Service Providers themselves and must comply with the same obligations — data persistence, third-party backup, and dynamic resolution systems. This is a viable but complex and resource-intensive path, which is why it is typically considered only by very large organizations.
The standard approach — and for the vast majority of companies, the most sensible one — is to rely on a specialized Digital Product Passport service provider or DPP-as-a-Service platform. The ESPR Regulation already foresees, under Article 11, the establishment of a certification system for DPP Service Providers.
By 2026, compliant providers will be required to obtain this certification, ensuring that their digital architecture meets all regulatory requirements: data persistence, backup systems, cybersecurity protections, resolution mechanisms, and data neutrality.
Choosing a certified DPP provider will therefore be the most direct way to ensure that your DPP is built to last — not just for the next few quarters, but for the entire lifecycle of the product.
A well-designed DPP must outlive the product it certifies, the company that issued it, and the servers that host it today.
If it is not built to last, it is not truly a DPP — it is simply a digital promise with a hidden expiration date.
