If the data in an aluminium product passport is incorrect, the passport is formally present, but materially unreliable. This can have consequences at multiple levels simultaneously: towards the supervisory authority that verifies the data, towards the customer who relies on it, and towards your own company if it later emerges that a claim about origin, composition or recyclability was unfounded.
This is not a matter of a single fixed sanction. The Regulation leaves the implementation of supervision and enforcement to the Member States, and exactly which supervisory authority in the Netherlands will verify and how strictly it will do so is not yet clearly defined. What can be described is: what types of consequences typically arise from incorrect product information, and why the accuracy of data carries more weight than simply having a passport.
Why accuracy carries more weight than presence
A product passport is intended to make data about a product verifiable and traceable: where the aluminium comes from, what proportion of recycled material it contains, and what properties are relevant for processing or reuse. A passport that exists but shows incorrect data undermines precisely that purpose. For a supervisory authority, a passport with an error is therefore a different type of finding than a missing passport: the first points to a control problem in the process of collecting and submitting data, the second to the absence of that process.
That distinction is relevant because most errors do not arise from unwillingness, but from inadequate transfer of data between manufacturer, importer and the party compiling the passport. Anyone wishing to ascertain what data are precisely needed for their product and where they should come from will find an overview by situation in the knowledge base with topics per business situation.
Consequences in contact with the supervisory authority
If a supervisory authority detects a discrepancy between what the passport claims and what is demonstrable, it is logical that a request for substantiation or correction is first made. Regulations of this type typically provide for a stepwise approach, in which correction often takes precedence. A ruling on what step follows in a specific case, what timeframe applies or what sanction is possible cannot be given here: that depends on the implementation by the competent supervisory authority and, where applicable, on what a lawyer advises in the specific situation.
Consequences in the relationship with customers and purchasers
Alongside supervision there is a second level that in practice is at least as noticeable: the customer who makes purchasing decisions based on the passport. A purchaser who uses a product passport to support their own chain often notices an error before a supervisory authority does. This can lead to questions, a request for remediation, and in some cases to a reconsideration of the supplier relationship. This occurs independently of whether a breach of the Regulation has also been established; it is a contractual and commercial consequence, not a legal-formal consequence.
Anyone wishing to see how such a data stream is structured in practice and where the information in a passport comes from will find that explained on the page how the data in a passport are compiled.
How errors typically arise
In practice, inaccuracies more often arise from a copy error, an outdated specification, or an incorrect link between a batch and a file than from intent. For example, a supplier delivers an updated alloy composition, but that update does not reach the party managing the passport. Or a product is resold under a different designation without the underlying passport being adjusted. This type of error is precisely why establishing a fixed, repeatable way of submitting data receives so much weight in discussions with software suppliers and internal responsible parties.
What you can do now
The most concrete thing a company can do now is to check which data are relevant for its own product, who manages them within the organization, and how changes in them are communicated to whoever compiles the passport. A number of frequently asked questions about this, including the source in the official text, are collected on the page with answers to frequently asked questions about the product passport.
Would you first like to see where your own situation roughly stands, without immediately creating an account? Do the free quick-scan via the product scan with an indication in a few questions or browse through the topics in the knowledge bank to see which step is most obvious for your company.