can I have the data in the product passport updated automatically

Automatic updates are possible, but not automatic themselves

Yes, data in the digital product passport can be updated automatically, but this does not happen by itself — it is something that must be set up. The ESPR requires that the passport contains current data and that it is technically possible to update information, but the regulation does not mandate automatic integration. Whether an update runs automatically depends on how the passport is technically configured: if it stands alone, someone updates it manually; if it is linked to a source system, a change there can flow directly into the passport.

For which data automation works and does not work

The distinction that matters here is between data that is fixed at production and data that changes during the product's lifetime. A technical characteristic such as material composition or a test result is established at the moment the product is made, and does not change thereafter — automatic updating is less relevant there, because there is nothing that changes. Other data is dynamic: a repair status, a change of owner, an update of a warranty period, or data that differs per market region. For such data, a link with a source system is valuable, because the passport then moves with what changes in practice, without someone having to enter that separately each time. Article 10 of the ESPR (Regulation (EU) 2024/1781) establishes as a requirement that the data in the passport is accurate, complete and current — that is the obligation to which automation can be a practical answer, but the regulation itself does not mandate the technique to achieve that.

What also does not apply here: replacing automation by simply making changes. Who is authorized to adjust which data, and how that remains demonstrable, is a different matter than the technique of updating itself. A link makes the process faster, but does not remove the responsibility to determine which data are correct.

When this becomes relevant is not yet fixed per product group

There is no fixed date on which automatic updating becomes mandatory, simply because the obligation to automate does not exist — what is established is the requirement that the passport must be current once it applies to a product group. When this comes into effect for each product group is determined per delegated regulation and thus varies per product. Until the moment that a product group falls under an obligation, no passport is needed and therefore no updating question arises. Once a product group does fall under the obligation, the requirement of accuracy and currency applies from that moment — the form in which this is technically resolved (manually or automatically) is up to the manufacturer or importer, within the technical frameworks that Article 11 of the ESPR (Regulation (EU) 2024/1781) sets for the functioning of the passport.

How this is tackled in practice

The first step is to determine which data in the passport actually change during the product's lifetime, and which are fixed. For the fixed data, automation is usually not necessary — they are entered once and remain in place. For the dynamic data, the next step is to look at whether there is already a system in which that information is maintained, such as an ERP system, an inventory system or a service administration. If there is, then linking the digital product passport to an ERP system or inventory system is the way to ensure that a change in the source automatically flows into the passport, without duplication of work.

After that, it is a matter of establishing who within the organization is permitted to make a change and how that change remains traceable — not because the regulations prescribe this as a separate process, but because a product passport that must remain available for ten years or longer can change owner or status multiple times during that period. This also raises the question of how long a product passport must remain available, and what happens to it if the data behind it changes — see how long a product passport must remain available. If you are compiling digital product passports for multiple product groups, it is advisable to set up the link in such a way that a change in the source system does not inadvertently affect the wrong passport, especially when a product falls under multiple passports at once falls.

The legal basis: articles 9, 10 and 11 of the ESPR

That the passport must contain current data follows from article 10 of the ESPR (Regulation (EU) 2024/1781), which sets accuracy, completeness and currency as requirements for the information in the passport. Article 9 of the ESPR (Regulation (EU) 2024/1781) describes what the digital product passport is substantively and what information it contains, and article 11 of the ESPR (Regulation (EU) 2024/1781) governs the technical design and operation of the passport, including the possibility to update data. None of these articles prescribes a specific technology or form of automation — the obligation is the result (current, accurate data), not the method by which that result is achieved.

Those wishing to see how a link with their own system looks in practice, or how a unique identification per product plays a role in this, will find that in the knowledge base; for the exact text of the articles, the official publication of the ESPR in EUR-Lex is the source to consult.