Yes, you can handle part of the digital product passport yourself: you typically gather the basic data on composition, origin, alloy and processing of your aluminium semi-finished product yourself, because only your own company or your supplier knows that information. The management that follows — keeping the passport online for years, linking it to a QR code on or with the product, and updating it whenever something changes — is a different matter. In practice, that is where the boundary lies between what companies continue to do themselves and what they outsource.
That boundary does not shift because preparing data is difficult, but because the regulation requires something most companies are not used to organising: a technical facility that remains accessible for years, even if something changes internally. Anyone wishing to assess this for their own situation would do well to first determine what management actually entails, before deciding whether to do it themselves or outsource it.
What management actually entails
Preparing a passport is a one-time or periodic action: you provide data, which is processed into a passport, and that passport receives a location. Management is something else. It concerns the period that follows: the server displaying the passport keeps running, the QR code on the product continues to point to the right place, and changes in composition or in the regulations are processed without the old data disappearing without trace. how that data is maintained during the term shows which steps are involved and where the information continues to come from.
What you can reasonably do yourself
In practice, a number of components lie close to what you already do for quality control or certification. Gathering and keeping current source data on alloy, processing and origin falls within this, as does designating one internal responsible person who knows where which data comes from. Following changes in the regulation itself — for example, when the delegated act for aluminium is published — is also something a company can monitor itself, although that is more a matter of staying alert than technical work.
Where doing it yourself hits a practical limit
The regulation requires that the passport remains accessible for a longer period, even when something changes internally: an employee leaves, a software supplier stops, or the company switches IT systems. A passport on your own server must then still remain accessible via the same QR code. That requires continuity that does not naturally emerge from an ordinary website or an internal document management system. In addition, data from different sources — an ERP system, quality certificates, data from a supplier — must come together in one traceable whole, and that remains correct even after years. Anyone wishing to set this up entirely themselves is essentially building their own long-term hosting facility, with everything that entails in terms of back-ups and security. how data and privacy are safeguarded in this process provides an understanding of what is needed for that.
The assessment that differs per company
Whether self-management is feasible for your company depends on factors that differ per situation: how many products are involved, how often the composition changes, and whether there is already an IT department that can structurally support this task. This is a business assessment, not a legal one; for the question of whether your specific approach complies with the regulation, the official text or a lawyer is the right point of contact, not a general article. worked out per subject what is relevant for your situation provides a starting point to explore that further, without you having to build everything yourself immediately.
Do it yourself, outsource, or something in between
In practice, many companies opt for a middle ground: the source data remains the property and responsibility of the company itself, while hosting, linking to the QR code, and long-term management are delegated to a party that has this as its core task. This does not necessarily save on the one-time effort of providing data, but it does save on the long-term obligation to keep something running for ten years. What this saves in time and costs varies by company and by number of products; an overview of the costs of outsourcing can be found on the page with rates and what is included.
Would you like to first get an impression of what you would need to do yourself and what not, before making a choice? in a few questions you can see where you currently stand, entirely without obligation and without having to provide data in advance.