A digital product passport is linked to a specific product, not to a snapshot from the past. If the composition changes, the origin of a component, or a test result, then that change must be reflected in the passport that can be consulted via the QR code. If you do not do this, a discrepancy arises between what the passport states and what the product actually is. The regulation states that the information in the passport must be accurate and up to date; what that means in a specific case and who monitors it depends on the product group and is ultimately assessed by the competent supervisory authority.
In practice, an outdated passport usually does not arise from unwillingness, but because no one within the company has been appointed to report changes. A new supplier of a component, an adjusted coating, a different battery cell: these are operational decisions that are often separate from the place where the passport is managed. As a result, the data falls behind the product without this becoming visible anywhere until someone actually consults the passport.
What is stated about timeliness
The regulation for digital product passports places the responsibility for accurate data with the market participant who had the passport drawn up — usually the manufacturer or the importer. This party is not only responsible at the time of placing on the market, but also afterwards, for as long as the product is available and the passport can be consulted. What exactly that requires varies by product group: for one passport it concerns repair information that may change, for another material composition that changes with a new production batch. A good starting point to see what is relevant for your situation can be found in the knowledge base with explanation per subject.
Where things can go wrong
The risk of an outdated passport lies in two places. First with the buyer or user, who makes a decision based on incorrect information — about repair, recycling, or warranty. Second with the company itself, when a supervisory authority discovers during an inspection that the data behind the QR code does not match the product. What the specific consequences of that are is not stated in general terms in the regulation; that is assessed on a case-by-case basis and per Member State, and the supervisory authority determines how to handle it.
In addition, a practical point applies: a passport that has not been updated is often also a signal that the underlying process is not in order. If you do not know which change should have been reported, you usually also do not know who within the company is responsible for that. This makes the problem bigger than one isolated passport: it then becomes a question of whether there is even a procedure in place to flag and process changes.
How a current passport works in practice
A product passport that grows with the product requires a fixed place where changes arrive and a short line to whoever manages the passport. At many companies, this is a matter of making agreements between purchasing, quality and whoever technically maintains the passport — not necessarily a new system. When a passport is hosted via a third party, such as prodpas.eu, a change is processed via a request to that party; how quickly that is processed and what is required for that is something to establish in advance with your supplier. If you would like to know how that processing works exactly, you can read that on the page about how the data is created and maintained.
For companies that are not yet sure whether their current process captures changes in time, a brief self-check is often enlightening. In a few questions you can see where your company stands, without any obligation being attached to it. That gives an initial direction, regardless of whether and how your specific situation complies with the regulation — that assessment remains the responsibility of a lawyer or the competent supervisory authority.
If you have doubts about a concrete situation, for example whether a certain modification to a product requires notification for the digital product passport, that is not something a general article can provide clarity on. The frequently asked questions address a number of such borderline cases, but for your own product, consultation with a lawyer or the supervisory authority remains the recommended approach.
If you want to get an initial understanding without taking steps immediately, do the free quick-scan or browse through the topics in the knowledge base. Both are freely accessible and provide initial guidance before you make further decisions.