Can a digital product passport be carried by an NFC tag?
Where the delegated act for that product group allows it. The ecodesign regulation defines a data carrier as a barcode, a two dimensional symbol or any other automatic identification medium a device can read, so a tag qualifies as a medium; which carriers apply to a given product is set act by act.
What the text calls a data carrier
regulation (EU) 2024/1781 defines a data carrier as a linear barcode symbol, a two dimensional symbol or other automatic identification data capture medium that can be read by a device. The definition names no technology beyond those two examples, which is what leaves the door open: an NFC tag is an automatic identification medium a device reads.
The choice is not left to the manufacturer either. Article 9 provides that the delegated act adopted for a product group specifies, among other things, one or more data carriers to be used, the layout in which the carrier is presented and its positioning. So the question for any given product is what its act says, and this site cannot answer it for you.
What the carrier has to satisfy
Article 10 sets the essential requirements. The passport is connected through a data carrier to a persistent unique product identifier. The carrier is physically present on the product, its packaging or the documentation accompanying it, as the act specifies, which the placement page takes up.
The carrier and the identifier also have to comply with standards named in Annex III, the ISO/IEC 15459 series, until references of harmonised standards are published. That is a requirement about identifiers and their issuing, not about radio: it applies whichever medium carries them.
What a tag brings, and what it does not
A tag is read without aiming, through a closed door of a package, and it survives the wear that makes a printed symbol unreadable, which matters when the passport has to remain reachable for the life of the product. It can also sit inside the object, where nothing can scrub it off.
What it does not bring is the data. The passport is stored by the economic operator or by a service provider, as the hosting page describes, and the tag carries the identifier that links to it. Anything else on the tag is your own addition, and the tag or server page weighs that choice in general.
Deciding for a given product
Read the act for the group, in that order: whether a passport is required at all, which carriers it names, where they go, and at which level the passport is established, model, batch or item, which Article 9 also leaves to the act and which the rest of this section keeps returning to.
Then decide with the object in your hand rather than with the regulation alone. A tag that has to survive moulding, washing or a metal body is a manufacturing question before it is a legal one, and the rest of this section covers it.
Frequently asked questions
Does the regulation mention NFC?
Not by name. It defines a data carrier as a barcode, a two dimensional symbol or another automatic identification medium a device can read, and leaves the specifics to each delegated act.
Can a product carry both a printed code and a tag?
Where the act allows it. Article 9 says the act specifies one or more data carriers to be used for the product group.
Does the tag store the passport?
No. It carries a persistent unique product identifier that links to the passport, which is stored elsewhere.
Which standards apply to the identifier?
Annex III names the ISO/IEC 15459 series for the data carrier and the identifiers, until references of harmonised standards are published.