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I have discovered an error in a product passport that is already online what now

Correcting an error is possible, and must also be done

Correcting an error in a published digital product passport is the normal course of action, not an incident that must be kept hidden. The ESPR assumes that the data in the passport remain accurate in relation to the product data, and this aligns with what is laid down in Article 10 of the ESPR (Regulation (EU) 2024/1781) regarding requirements for the digital product passport: the information must be accurate. An error that remains after it has been discovered is a different problem than the error itself — that is the moment when it can shift from "mistake" to "negligence". Correcting as soon as it becomes apparent is therefore the core of the answer: not waiting, not weighing whether it is worth the effort, but having the data adjusted.

Which errors this applies to, and which it does not

This concerns errors in the content of a passport that has already been published and linked to a product: an incorrect value, an incorrect component, an outdated certificate, a repair instruction that is no longer accurate. This is a different situation from a passport that is not yet online — there a mistake is simply a matter of correcting it before it goes out the door, without anything needing to be "repaired". It is also a different situation from doubt about which data should actually be included; those seeking clarification on whether particular data is mandatory or not will find that overview in which data will be included in the digital product passport of products. And it is something entirely different from a discussion about the measurement method itself — if the value has been correctly calculated according to the prescribed method but still has an undesirable outcome, that is not an "error" in the sense of this article but a question about the method by which values must be measured.

This does not concern data that have been deliberately restricted for certain target groups — a value that a repair technician sees but a consumer does not is not an error but a matter of access rights, with a logic that stands separate from this question.

There is no correction deadline in the text, but rather an ongoing obligation

The ESPR specifies no particular deadline within which an error in a published passport must be corrected. What is clear: the obligation to display accurate, up-to-date and complete information is not a snapshot at publication, but something that continues to apply as long as the passport is active. This follows from the same Article 10 of the ESPR (Regulation (EU) 2024/1781), and it aligns with the logic behind data maintenance in general — how often and at what time data must be updated is described in how current the data in the product passport must be. Until the moment of correction, therefore, inaccurate information remains online, and that is precisely the period in which the risk lies: not in the fact that the error was ever made, but in the time during which it remains visible and uncorrected.

How this is handled in practice

First, it is established what exactly is wrong: an incorrect value, an incorrectly linked document, a typo in an identification number, or something structural such as an incorrect product category classification. This distinction determines how extensive the correction is — a typo is different from an error that suggests the underlying measurement is not correct.

Then it is checked whether the error stands alone or whether it also affects other passports, for example when the same incorrect value has been used for an entire product line. With repeated errors, the cause often lies not in the passport but in the process behind it — the measurement, the data source, or the way data are transferred from internal systems.

Subsequently, the correction is made in the passport itself, without changing the QR data carrier or the link with the product: the code remains the same, only the content behind it is adjusted. This is also immediately the reason why a digital product passport is more practical than a printed document — the information is corrected at the place where it exists, not by distributing a new copy.

After that, it is necessary to check whether the error has had consequences outside the passport itself: for example, has communication been made to a customer, a business partner, or in advertising based on the incorrect value? That is a separate question, separate from the correction in the passport.

Finally, it is recorded when and why the correction was made. Not because that is now already required in writing for this precise situation, but because a trail of "what did I know, when, and what did I do with it" is in virtually every supervisory framework the basis on which a distinction is made between a mistake and negligence.

The legal basis: Article 10, in conjunction with Article 40

Article 10 of the ESPR (Regulation (EU) 2024/1781) sets the substantive requirements for the digital product passport, including that the data must be accurate — that is the basis on which an error is an error in the first place. Article 9 of the ESPR (Regulation (EU) 2024/1781) describes what the passport as a whole is and how it must function, which is relevant once an error does not stand alone but points to a problem in the structure of the passport. Article 40 of the ESPR (Regulation (EU) 2024/1781), on the prevention of circumvention and performance degradation, is relevant in the case that an "error" on closer inspection was not a mistake but a value that was deliberately presented as more favorable than reality — that is a different order of things than a typo, and is also assessed differently. Article 39, on test, measurement and calculation methods, is the background against which it is assessed whether a value that seems "wrong" really is, or whether it is the result of a correctly applied method.

If someone has now found an error, it is best to first locate it — which data, in which passport, since when — and then have the correction made via the party hosting the passport, without changing the QR code or product link. In case of doubt as to whether it is an error or a methodological matter, the official text of the ESPR via the legal basis above has the final word.

What you must do concretely

What is expected of you

An error in a published passport is not an incident that you set aside until the next scheduled update. The ESPR is based on the idea that the passport at any time provides an accurate representation of the product to which it is linked, and that expectation does not change because the error was already there on the day of publication.

The data must be correct at the moment they are accessible

Article 9 of the ESPR (Regulation (EU) 2024/1781) describes the digital product passport as the carrier of product information that is accessible via the data carrier to the parties entitled to it. A passport that is online with an incorrect value, a wrong part number or a data point that belongs to the wrong model, does not at that time meet what is expected of the content. For a company with 10 to 100 employees, this means in practice that an error report — from a customer, an importer, a business partner or an internal audit — does not end up in a queue, but is a direct reason to look at what is wrong and whether it needs to be corrected. Which data exactly fall under this expectation depends on the product group; which data goes into the product passport of products provides an overview of this.

The underlying measurement method must be justifiable

Article 39 of the ESPR (Regulation (EU) 2024/1781) provides that the values in the passport are produced via documented test, measurement and calculation methods. An error in a published passport is not always a typo — sometimes the error runs deeper, in the measurement or calculation on which the published value is based. For a company, this means that a correction sometimes does not stop at adjusting a single number in the passport, but asks for a look at the file from which that value came. How these measurements must be performed is described in according to which method must I measure the values for the passport.

The responsibility for accuracy remains with whoever compiled the passport

Article 10 of the ESPR (Regulation (EU) 2024/1781) establishes who has which role in preparing and making the passport available. The platform that hosts the passport does not change the data on its own initiative; the party that compiled the passport — typically the manufacturer or importer — remains accountable for the content, even after publication. For a company, this means that a reported error must be routed internally to someone with the authority to make a correction, and must not get stuck between customer service and technical departments without anyone actually implementing the adjustment.

Corrections may not make the product's performance appear better than it is

Article 40 of the ESPR (Regulation (EU) 2024/1781) is aimed at preventing circumvention and artificial enhancement of measured performance. This article is primarily written against manipulation during testing, but the underlying principle also applies to correcting a passport: correcting an error is different from adjusting a value in a direction that makes the product appear more favorable without the underlying measurement justifying this. For a company, this means that every correction must be traceable to an identifiable reason — a new measurement, an identified omission, a correction of a link error — and not to desirability.

Where things go wrong in practice

A common situation is that the error is identified, but nobody within the company knows who is authorized to modify the passport. The data is on the platform, but the authority to change it lies with a department that was not involved in the original submission.

A second situation: the error is corrected in the internal system, but not transferred to the published passport, because the assumption is that periodic synchronization will automatically resolve this. How often an update must actually take place and whether this coincides with your own expectations is explained on how often must I update the data in the digital product passport.

A third situation arises when the error is in data about repair or parts — for example an incorrect part number for a replacement part. Such errors are often discovered late, because nobody consults the passport until a repair is actually needed. What exactly should be in that section of the passport is described on do I need to include information about repair and parts in the product passport.

A fourth situation: the error turns out to be in a translated version of the passport, while the original language version was correct. Because translations sometimes follow a separate process, the error is corrected in one language but not in another. More about the language obligation is on must I offer the product passport in multiple languages.

A fifth situation arises when an external party — a business partner, a recycler, a regulator — identifies the error, but the company does not know which party actually had access to which data and therefore cannot assess how widely the error spread. Who may view which data is explained on who may view which data from the product passport.

What you can document

  • An internal designation of who is authorized to modify a published passport, including a substitute contact person during absences.
  • A brief log for each passport showing which change was made, on what date, and on what basis — a complaint, an internal review, a new measurement.
  • The underlying test report or calculation that forms the basis of the corrected value, so that the correction remains traceable to an identifiable source rather than a loose adjustment.
  • A fixed channel for error reports from outside the company — customer, importer, business partner — so that a report does not get lost between departments.
  • A check that after each correction confirms that the adjustment is actually visible in the published version consulted by customers, and not only in the internal source system.
  • If in doubt whether a detected discrepancy falls under the mandatory content of the product passport at all: a reference to does the digital product passport apply to my products to establish whether the product and the data actually fall under the regulation.

This is not legal advice. This page provides general information about the regulations that this platform concerns. We do not know your situation. If you are in doubt about your own case, consult a lawyer or the competent supervisory authority.

Written with AI based on the sources above, reviewed by a human on 2026-09-05. Is something incorrect? Let us know — corrections are given priority.