If you sell aluminium products in multiple EU countries, the structure of the digital product passport itself does not change: the regulation is EU law and applies in each Member State in the same way. What can differ is how the supervisory authority in that country operates, what language the accompanying information must have, and how your provider has arranged hosting and data storage for international sales. These are precisely the points worth singling out separately in your conversation with your software provider.
The reason this distinction is often overlooked is that providers usually sell their system as one EU-wide product. That is also correct for the core of the passport. But the way in which the data is displayed and checked is not regulated identically everywhere, and that is precisely where companies with export activities sometimes run into problems they did not anticipate.
The passport itself does not differ by country
The underlying regulation (ESPR) is a European regulation, not a directive. This means that Member States may not adapt the content themselves: what data is mandatory, how long the passport must be kept and what the QR data carrier must show is fixed at EU level. For your software provider, this means that one correctly set up passport in principle has the same basis everywhere in the EU. If you want to see exactly what data belongs in it, you will find that overview in the knowledge base by topic.
What can differ by country
What is not in the regulation itself is how the national supervisory authority organises the inspection and who you contact there. Also, separate from the product passport, other national requirements may apply that have existed for longer, for example in the field of labelling or language of accompanying documentation. These requirements do not come from the product passport regulation, but they do play a role as soon as you sell in multiple countries. A software provider that only builds for the Dutch market does not always think of this automatically. Answers to this type of demarcation questions per situation can be found under the most frequently asked questions about the passport.
Concrete questions for your conversation with your provider
If you sell internationally, it is worthwhile to ask your software provider specifically how the system handles multiple languages in the display of the passport, whether the QR data carrier is equally readable for market surveillance in other Member States, and where the underlying data is physically hosted. The latter not only affects the product passport obligation but also data protection in a broader sense: where servers are located and who has access is relevant as soon as you work with parties in multiple countries. How this is arranged for a passport from alupas.eu, you can read on the page about how data is protected.
Another point to discuss is who is responsible for updating the passport if a product is placed on the market in another country through an intermediary. The role of manufacturer, importer or distributor can shift per sales channel, and this also determines who must supply which data. If you are unsure where your company stands in that chain, a brief run-through of the product scan with an initial indication will provide guidance before you enter into the conversation with your provider.
What this article does not do
This text describes where the key points of attention lie if you sell internationally; it says nothing about your specific situation. Which national requirements in addition to the regulation apply to your products and which supervisory authority in another country is competent varies from case to case and from country to country. For this, please consult the competent supervisory authority in the country concerned or a lawyer familiar with cross-border sales.
Would you like to first get a picture of what changes for your company, even if you sell outside the Netherlands? Go through the free quick-scan or browse through the topics in the knowledge bank; that takes you a few minutes and gives you an immediate direction.