The most common error
The most common mistake in the QR code of the digital product passport is not that the code itself does not work, but that the link behind it does not move with the product. Companies have one QR code printed for an entire product line, while the regulation assumes data that belongs to a specific product or a specific batch. If something changes in the product — a different supplier for a component, an adjusted composition — then the information behind the code is no longer correct, while the code itself continues to scan just fine.
This error usually does not arise from carelessness, but from a wrong assumption: that the QR code is a fixed label, like a nameplate. In practice, the code is mainly a reference to something that must remain correct, for years, even if the product has long been sold and changes hands.
Why this goes wrong
The QR code is often seen as the last step: first gather the data, then have the code made and printed on the product or packaging. As a result, the code is treated as a technical detail, while the real question should be: who updates the underlying data as soon as something changes, and how does that change reach the code without you having to reprint or relabel?
A second cause is placement. A QR code that is on a removable sticker, on packaging that is thrown away, or on a location that wears out before the product is written off, does not meet the requirement that the information must remain available throughout the product's lifetime. This is not a matter of carelessness, but of a choice that is made at the wrong time in the process — often by the packaging department, without anyone having made the connection to the passport.
What the regulation does and does not specify
The regulation for digital product passports sets requirements for the data carrier, such as readability and durability, and for the fact that the information must remain accessible for a certain period. How these requirements are precisely filled in per product group varies and is partly still being worked out further. It is therefore not possible to say in general which technical standard applies to your product; you can best read that in the official text or ask the supervisory authority for your sector.
What does apply to all product groups is the underlying principle: the code is a reference, not a storage device. The data itself is stored elsewhere, and the code must reliably continue to point to it. If you confuse this with "the QR code is the passport", you run the risk of asking the wrong questions to a supplier or software partner. In the knowledge bank per topic you will find per product group what is known about the data carrier and where that is stated in the official text.
How you prevent this
The core of the solution is separation between the code and the content. The QR code itself does not need to change as long as it points to an address where the current data is located; what needs to change is only what is available behind that address. This means that at the start of the project you must already establish who is responsible for keeping the data up to date, and how a change in the product — a different raw material, an adjusted component — reaches the passport without the physical code having to be reprinted.
It helps to have this conversation before the packaging or the nameplate is finalized, not after. Ask whoever prints or has the code printed: is this code unique per product or per batch, and does that align with how the data are maintained? Those who haven't yet clarified this can use a few short questions to see where the bottlenecks are before irreversible choices are made about packaging or labelling.
What if the mistake has already been made
If it turns out that a QR code has been applied too generically, or is located in a place that is not durable for the product's lifetime, this can usually be remedied without having to start everything over. The first step is to establish exactly what is currently behind the code and whether that still aligns with what is being sold. After that, it is a matter of restoring the link, not necessarily replacing the code itself. In how we collect and keep the data current you will read how such a link is arranged in practice, so that a change in the product does not lead to the same mistake again.
Are you uncertain whether your current approach touches on this pitfall, or do you have questions about a specific product group? Do the free quick-scan or read the topics in frequently asked questions about the digital product passport — for the situation of your own company, the official text or the competent supervisory authority remains the appropriate point of contact.