Does a passport carrier have to be on the product itself?
Not always: Article 10 allows the carrier on the product, on its packaging or on the documentation accompanying it, as the applicable act specifies. The regulation reasons that the product itself keeps the data reachable for its whole life, which is what packaging cannot do.
Three allowed places
Article 10 of regulation (EU) 2024/1781 requires the data carrier to be physically present on the product, its packaging or on the documentation accompanying the product, as specified in the applicable delegated act. The act chooses, and it also specifies the layout in which the carrier is presented and its positioning, which Article 9 lists among the things it settles.
So three places are possible in the abstract, and one is named for a given group. Designing before reading the act is how a tooling change arrives late.
Why the product itself
The regulation explains its preference in its recitals: the data carrier should be on the product itself to ensure the data remain accessible throughout its life. Packaging is discarded at the first use, and documentation is lost long before a product reaches a repairer or a recycler.
Read beside the availability requirement, which the availability page covers, the logic is consistent: a passport that has to outlive the company cannot depend on a box that outlives nothing.
What that costs in a real object
A carrier on the product is a design constraint. A printed symbol needs a flat, durable, visible surface; a tag needs a position where the antenna is not shorted by metal and not crushed by assembly, which the metal page explains from the failure side and which the rest of this section takes product by product.
It is also a constraint on the process. A tag applied after painting, moulding or curing survives differently from one placed before, and the moment of placement is usually decided by the line rather than by the designer.
Deciding in the right order
Read the act first, then the object, then the line. The act says where the carrier may go; the object says where a tag can live; the line says when it can be placed and what it will endure.
A prototype settles the last two, with the tag in the finished casing rather than on a bench, and it is worth running before tooling rather than after a first production batch has been made.
Frequently asked questions
Can the carrier be on the packaging?
Where the act allows it. The regulation permits the product, its packaging or the accompanying documentation, and the act chooses for the group.
Why does the text prefer the product?
Because the data has to remain accessible for the product life, and packaging and documentation are discarded long before that.
Does the act say exactly where on the product?
It specifies the layout in which the carrier is presented and its positioning, so the detail comes from the act rather than from convention.
When should the tag be placed on the line?
Early enough to survive the process and late enough to survive handling. A prototype answers that better than a drawing.