The short answer
Yes, as a manufacturer or importer, you can collect the data for a digital product passport yourself. Nothing in the regulation obliges you to engage an external party for this. You know your product, your suppliers and your technical documentation best, and many companies therefore start internally: what materials are in it, where do they come from, what repair and recycling information is already available.
Where it becomes more difficult is not the collection itself but what happens afterwards: putting the data in the correct, machine-readable format, linking it to a register, and ensuring that the QR code continues to point to a working page for ten years. These are not legal obligations to outsource, but they are parts where doing it internally in practice requires more time and knowledge than most companies estimate beforehand.
What you can reasonably do yourself
The core of the passport is factual knowledge about your own product. Material composition, origin of components, repair manuals, warranty periods and recycling instructions: this is information you probably already have somewhere, scattered across procurement files, technical drawings and quality documents. Bringing those documents together is work that can easily be done internally, especially if you know which data category is mandatory for your product group.
In the knowledge bank by subject it is set out per product group which data are requested, so you do not have to guess whether something is relevant or not. This saves time in the collection process and prevents you from discovering later that something is missing.
What is deliberately not free
The detailed implementation of each requirement, with the associated deadlines and templates to record everything, is behind a subscription. This is not a sales trick but a practical choice: the short answer and the risk indication per topic are free, even without an account, with a reference to the official text. If you want to know how far you have already come with what you have collected, you can see in five questions where you stand, without needing an account for that.
Where doing it yourself becomes more difficult
Two parts require more than just providing data. The first is the technical format: a product passport must be machine-readable and aligned with the registers that the European Commission is setting up. This is not a matter of emailing an Excel file, but of a structure that is recognised by systems. The second is continuity: the QR code must continue to point to a working, up-to-date page throughout the entire retention period, even if your company switches software providers or a product is modified.
The regulation distinguishes between responsibility for the content of the passport and its technical implementation. Whoever supplies the data remains responsible for its accuracy, even if the technical storage and QR data carrier are provided by another party. That distinction is precisely why many companies do the content collection themselves and outsource the technical side: not because it would not be permitted to do it themselves, but because maintaining a register link and a ten-year hosting obligation requires different expertise than knowing your own product.
A practical consideration
Whether it is wise to do it yourself depends on how many product groups you have, how often your products change, and whether you already have a system in which technical documentation is maintained in a structured way. A company with one stable product in one product group faces a different consideration than an importer with dozens of items in multiple categories. What helps in both cases is first to clarify which data you already have and which are still missing, before you decide who does which part of the process.
How the data from your submission reaches the product passport, and which steps are involved, you can read explained on the page on how the information is created. If you still have doubts about a specific point, the most frequently asked questions are clearly listed together on the page with frequently asked questions.
For the application to your own situation, and for the question of what is precisely mandatory for your products, a lawyer or the competent supervisory authority remains the appropriate contact point. This article describes the general line, not your specific case.
Look further yourself
Would you like to first get an impression of where your company stands before you make a decision about doing it yourself or outsourcing? Take the free quick-scan or browse through the topics in the knowledge base; both give you a concrete picture within half an hour without committing yourself immediately.