The most common mistake in informing staff about the aluminium product passport is that only one person — often the quality manager or the buyer — is informed, while the people who change the underlying data daily know nothing about it. Think of someone on the shop floor who uses a different alloy, a buyer who switches suppliers, or the sales person who commits to a new batch with slightly different specifications. If they don't know that this change needs to be reported somewhere, the passport silently and unnoticed becomes outdated.
You prevent this mistake not by giving everyone an extensive course, but by clearly answering one question for each function that deals with the product: who must report a change, and to whom? That is usually enough. The regulation itself does not require training; it is a practical problem that arises because no one has been explicitly designated.
Why this goes wrong so often
Companies often treat the product passport as an IT project or a legal file: something that is "handled" by an external party or a single internal responsible person. That is correct for the technology — drawing up, hosting and linking the QR data carrier can be outsourced without any problem. But the data in the passport does not originate with the software supplier. It originates on the shop floor, in procurement and in sales. If those involved are not included, they cannot signal when something changes.
The result is that the passport is correct on the day of delivery, and then gradually falls behind reality. Nobody notices this immediately, because the passport remains perfectly scannable and displays neat data — only they are no longer quite correct. This risk is further elaborated in the knowledge base on the page about what happens if data is no longer correct.
What actually goes wrong on the shop floor
In practice we see three recurring situations. The first: a production employee adjusts a process parameter without realizing that this affects a passport data, because nobody has told him that this is relevant. The second: a new employee receives a tour and an induction schedule, but nowhere is it mentioned that the company operates a digital product passport and who is the contact point for it. The third: the information does take place, but only once upon implementation, and then disappears from the induction process for new colleagues.
In all three cases, the problem is not that people are unwilling, but that responsibility is not explicitly assigned anywhere. That is different from insufficient knowledge of the regulation; it is an organizational problem that occurs as soon as a task is linked to a person rather than to a function, and that person changes jobs or is on holiday.
How you prevent this
The core of the solution is simple: link the responsibility to a function, not to a name, and repeat the information for every new employee who works with the product. This does not have to be a separate training — a fixed part in the induction schedule, with one page of explanation and a clear reporting point, is usually sufficient. What is especially important is that people know what a change is that must be reported, not that they know the entire regulation.
Before you set up an information session, it is useful to first clarify which data is in your passport and where it comes from. After all, this determines exactly who needs to be informed. You get a first impression of this with a few questions that provide an immediate indication of your situation. Companies that have already discussed integration with their software supplier would do well to ask the same question — who reports changes, and how — internally with their own staff as well.
Not a substitute for legal advice
This article describes a common organisational risk, no legal obligation and no statement about your specific situation. What is needed for your company depends on your products, your processes and the final delegated act, which is expected to be published in 2027. For a legal opinion on your own situation we refer you to a lawyer or the competent supervisory authority. General background on how we collect and process data can be found on the page where the information in the passport comes from.
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