A digital product passport is not a document that you draw up once and then set aside. If anything changes in the product that is stated in the passport — a different alloy, a different raw material supplier, an adjusted production process — that change must also be in the passport. If the passport falls behind reality, it contains data that no longer apply to the product that is on the market. The regulation is precisely aimed at that link between product and information, and that link is broken if the passport does not match what was actually made or supplied.
The consequences of this are not primarily a fine that you can calculate immediately — those figures are not fixed and are filled in per country. The consequence that is concrete: a buyer, a supervisor or another link in the chain who consults the passport receives information that no longer matches. This can concern the composition of the alloy, the origin of the recycled share, or technical properties that determine whether the material is suitable for an application. If someone relies on it and it turns out to be incorrect afterwards, they are faced with a problem that is larger than just an administrative error.
Why updating the passport is necessary
The product passport is intended to show everyone in the chain — from foundry to end user to recycler — what is in a product and where it comes from. That function only works if the data are current. A passport that was created on the basis of a formulation that applied three years ago, while the alloy has since been adjusted, gives a misleading picture to anyone who consults it. This not only affects your own company, but also the parties further down the chain who rely on that information. The knowledge bank per subject sets out which data exactly fall under the regulation as part of the passport and which of these are subject to change.
What goes wrong in practice
In practice, an outdated passport usually does not arise from unwillingness, but from a gap in the process. A change in the formulation is properly recorded internally for quality purposes, but nobody automatically links that to the passport that has already been issued with earlier deliveries. Or a new scrap supplier changes the share of recycled aluminium without anyone feeding that back into the published data. With a growing company with multiple product lines, that risk is greater, simply because there are more changes running at the same time and less overview of which passport belongs to which batch.
Who is affected if the passport falls behind
The party that had the passport drawn up — usually the manufacturer or importer — bears responsibility for the accuracy of the data. But the consequences of an outdated passport extend beyond that one party. A buyer who processes the aluminium in their own product unintentionally builds on inaccurate information. A supervisor who checks whether the data match the product, not the intention with which the passport was originally set up. And a recycler at the end of the product's life needs current composition data to process the material correctly. If you want to get an idea beforehand of what is relevant for your situation, the product scan with a few questions provides a first indication, without you incurring an obligation.
What supervision means in this
The regulation places the obligation for a correct and up-to-date passport with the supplier, but who exactly checks that and in what way is up to the competent authority in the relevant EU country. At the time of writing, the Netherlands has not yet published a definitive arrangement for this. What is certain: a passport that no longer matches the product is a different matter than a passport that simply does not exist yet. Both situations can receive attention from a competent authority, but the nature of the problem — and therefore also what is needed to resolve it — differs.
How you prevent this in practice
The core of preventing an outdated passport does not lie with the technology of the passport itself, but with the process behind it: who within your company knows when a change in the product also means a change in the passport, and who communicates that to the party that manages the passport. When speaking with a software supplier or hosting party, it is therefore useful to ask how changes are processed and within what timeframe that happens. More about how that data flow works in practice can be read on the page about where the information in the passport comes from. For questions that come up frequently at companies dealing with this for the first time, the collection of frequently asked questions is a good starting point.
If you need a concrete picture of where your own situation stands, take the free quick-scan or browse through the topics in the knowledge base. For an explanation of your own situation and the question of whether and how these obligations apply to your company, a lawyer or the competent authority remains the appropriate point of contact.