The short answer
Yes, you can prepare part of the digital product passport yourself: collecting product data, maintaining technical documentation and determining what information the regulation requires for your product category. Where it becomes more difficult is the technical part: the passport must be in a fixed, traceable format, remain accessible for ten years or longer via a QR data carrier, and be kept up to date as long as the product is on the market. The latter requires hosting, version control and a working link between product and data — something most companies do not have as a core activity.
Whether it is sensible to arrange it yourself for your situation depends on how many products and product categories you have, how often specifications change, and how much time you can free up internally to maintain them. This is not a legal question but a practical consideration, and you are best served making this assessment after an initial inventory of what is exactly required of you.
What you can do yourself
Collecting the basic data is work that no one else can do for you: only you know what materials your product is made of, which suppliers are involved and what technical documentation already exists. Also appointing a responsible person within your organization — someone who knows where the data comes from and who is the point of contact for questions — is something you arrange yourself, regardless of whether you outsource the rest.
You can also find out yourself which obligations apply to your product category. The regulation works with delegated acts per product category, and not every category receives a passport at the same time or in the same way. Those who want to find this out themselves will find in the knowledge base with explanations per topic an overview by situation, including the location in the official text.
Where arranging it yourself stops
The regulation sets requirements for how the passport is technically offered: a unique identification number, a data carrier that remains scannable, and a structure that machines can read without a human having to interpret the text. This is not a matter of putting a PDF on your website. There must be a system behind it that keeps the data available for the long term, even if your own website changes, your hosting provider stops, or your company switches administrative systems.
In addition, the data must remain up to date. If a specification changes, the passport must change with it without the QR code or identification number changing — otherwise the link between product and passport no longer works. For a company with one product line, this is manageable. For a company with products in multiple categories, each with its own rules and its own change moments, keeping it up to date quickly becomes a task that remains alongside daily business operations.
What a supplier takes over from you
A platform such as prodpas.eu compiles the passport from the data you provide, hosts it for the required period and supplies the QR data carrier that meets the technical requirements. The work that remains is exactly the part that only you can do: supply the correct data and keep it up to date when something changes. For those who want to see how this division works in practice, on an explanation of where the data comes from and how it is processed a step-by-step description.
What a supplier does not take over from you is the responsibility for the accuracy of the data itself. Whether you build the passport yourself or have it compiled, the manufacturer or importer remains responsible for the content on it. Outsourcing thus shifts the technical work, not the liability for incorrect or outdated information.
Do it yourself, do it partially, or outsource it
For companies with one simple product and few changes, managing it yourself can be a realistic option, provided there is someone who can guarantee compliance with the technical requirements for the data carrier. For companies with multiple product groups, varying specifications, or limited internal capacity, it makes sense to outsource the technical part while maintaining control over the data yourself. Which situation applies to your company cannot be answered in general terms — it depends on your products, your processes, and the categories in which you operate.
If you are uncertain about how your own situation applies, the most frequently asked questions about this regulation you will find answers to a number of recurring dilemmas. For an individual assessment of your own liability, a lawyer or the competent supervisory authority remains the appropriate contact.
Would you like to first see where your company roughly stands before you choose between doing it yourself and outsourcing? With a short scan that provides an indication in a few questions you get a free initial overview for free, without needing an account for it.