There is no fixed deadline in the regulation that specifies within how many days an updated product passport must be ready. What does create a deadline in practice is the time you yourself need to collect the correct data, have it approved and pass it on to the party that updates the passport for you. That processing time usually ranges from a few days to several weeks, depending on what exactly has changed.
The regulation does require that the information in the passport matches the product as it is on the market. If something changes in the product, the passport must reflect that. How quickly that is arranged in practice is largely determined by you — by how your company is set up for this kind of updates, and not by the law.
What counts as a change
Not every adjustment to a product requires a new passport. A change of supplier for a component with the same specifications is different from a new material composition, a different repair process, or an amended durability guarantee. The regulation distinguishes between data that describes the product as a whole and data that may differ per unit or batch. Which changes are relevant for your products depends on the product group and the delegated rules that will apply to it. Anyone who wants to check this for their own situation will find in the knowledge bank by subject the source in the official text.
Where the processing time comes from
The time rarely lies in the technical processing of a change. That step, updating the data behind the QR code, is usually a matter of days. Where the processing time actually lies is before that: collecting the correct data from a supplier, getting an amended specification approved internally, and deciding who within the company may say that a change is significant enough to update the passport. At an installation company with multiple product lines, that often goes through the purchasing department; at a smaller company it is often one person doing it alongside other tasks. Both can work, as long as it is clear who identifies the moment.
Where it gets stuck in practice
Most delays do not occur during the update itself, but during the submission. A supplier who can only send a certificate after a few weeks, an internal department that does not know that a change is passport-relevant, or a software provider that does not automatically link to a product change: these are the moments when an update that could technically be ready in a day takes weeks. The conversation with your software provider about how changes are communicated and processed is therefore at least as important as the conversation about the initial setup of the passport.
What you can arrange in advance
What shortens the processing time most is a fixed procedure within the company: who reports a change, where does that report go, and within what timeframe is it processed. That does not need to be a heavy process — for many companies a fixed contact point and a short checklist of what makes a change passport-relevant is sufficient. Companies that have already had their first passport compiled often find that a second or third update goes faster, simply because the data and contact persons are already known. Anyone who still needs to determine what that process looks like can use a few questions to see where the company currently stands and from there map out a route.
The ten-year hosting period that comes with a digital product passport means that a product needs a valid passport throughout that entire period — not only at initial deployment. How this process is arranged behind the scenes and where the data comes from is explained on the page on how data is processed. For the question of whether a specific change in your situation requires an adjusted passport, the official text of the regulation or a lawyer remains the appropriate point of contact; this article describes only the general picture.
Would you like to know what a modification process could look like in practice for your products, or do you have a question that was not addressed here? Take the free quick-scan or browse through the answers to frequently asked questions to see if your situation is already covered.