If the continuity of your digital product passport is not arranged, and the hosting lapses due to a switch, a supplier's insolvency or simply negligence, then the QR code on your product can no longer be traced back to the data that should be behind it. The obligation to keep that data available does not disappear with it: it remains with the market operator, not with the party that hosted the passport.
That is the key point that many companies underestimate. A product passport is not a separate IT project that you implement once and then forget about. It is an ongoing obligation, linked to the product itself, and that obligation continues for as long as the product is on the market or in use. Those who do not arrange this in advance often only discover the risk when it becomes a problem: during an inspection, following a complaint from a customer, or when the supplier closes down.
What continuity actually means
Continuity for a digital product passport concerns three things at once: the data must be preserved, the QR code must continue to point to a working page, and that page must display the correct, up-to-date information. If one of these three falls away, the passport is effectively no longer available, even if the other two are still correct. A QR code that leads to an error message is no different from a missing passport for a supervisory authority or a customer.
The regulation leaves the precise retention period and technical implementation dependent on the product group; what exactly applies to your products is set out in the delegated legislation for each category. What does consistently come up, however, is that availability does not stop as soon as the product leaves the factory. For how this is implemented in practice, you can read how the data is stored and where it comes from.
Who remains responsible, even in the event of a switch
A common assumption is that responsibility moves to the software supplier once they technically host the passport. That is not how the role distribution in the regulation works: the market operator who puts the product on the market remains accountable for the availability of the passport, regardless of who provides the technology. The supplier is an implementer, not the party that bears the obligation.
This means that a switch to a different provider, or the cessation of an existing supplier, is not a technical detail but something you must monitor yourself. The relevant questions are set out in the knowledge base with explanation per subject, including what happens to the data in the event of a switch and how you enforce this in advance in a contract.
What is concretely at stake
The most obvious risk is that the product is no longer provided with a working passport at the moment it is requested, whether by a supervisory authority, a major customer or a consumer scanning the QR code. What the consequences of that are in practice depends on the supervisory authority responsible for your product group and country, and this article does not make a prediction on that.
In addition, there is a more practical risk: if a supplier stops without an agreed handover, it can take months before the data is back in order, simply because gathering the underlying documentation takes time. Companies that have already gone through that process know it goes faster if the source documents are well archived, regardless of which platform is hosting them at any given time.
What you can arrange now
Most continuity risks can be limited by making three arrangements in advance: who manages the source data, how it is transferred when changing suppliers, and what happens if the supplier itself stops. These are not legal questions that only a lawyer can answer, these are contractual arrangements that you can already include now, or check in an existing contract.
Whether your own situation is sufficiently covered, and what exact deadlines apply to your product group, is something for which you would do best to consult a lawyer or read the text of the regulation itself. If you first want to get an impression of where you stand now, then you can get an indication of your situation in a few questions, or read the frequently asked questions for a first orientation.