The mistake in brief
The most common mistake we see at companies is that the digital product passport is filled in as a standalone document, without aligning it with data that already exists: the declaration of conformity, the instructions for use, the safety data sheet, or the technical documentation that goes with the CE marking. The result is that the same property of the same product is described differently in two places, for example a different material composition, a different weight, or a risk classification that does not match.
This contradiction usually does not arise from carelessness, but because the data comes from different sources and is managed by different people. The technical department manages the CE marking file, procurement provides data on origin and materials, and the digital product passport is often taken on as a separate project, sometimes by a different colleague or an external party. Without a fixed process to compare these sources, differences go unnoticed until someone puts them side by side.
Why this goes wrong so often
The regulation for the digital product passport is separate from the rules for CE marking and product safety; the passport does not replace that documentation, but exists alongside it. This distinction is clear in the text of the regulation, but in a company's practice the two processes easily get mixed up, precisely because they concern the same product and often use the same basic data. If you do not establish in advance which source is leading for which data, you run the risk that updates to the technical documentation do not automatically carry through to the passport, or vice versa.
A second cause is time pressure. When the passport is put together shortly before a deadline, there is little opportunity to systematically check data against existing files. The data is then retyped or re-estimated instead of taken from the source that was already there. the knowledge base with explanations per topic addresses what a product passport must and must not contain, which helps prevent this confusion in advance.
What goes wrong in practice
Specifically, we see three situations recurring. First, a material composition that is stated differently in the passport than in the safety data sheet, for example because a supplier has changed a raw material midway and that has only been updated in one of the two documents. Second, a product version that still shows the old version in the passport, while the technical documentation has already been updated following a design change. Third, data that is factually correct, but does not align with the classification that safety supervisors use, making a comparison between the two documents unnecessarily difficult.
None of these situations is dramatic in itself, but they make it harder for a supervisor to quickly see that the documentation is consistent. Supervisors check, among other things, the coherence between the different mandatory documents of a product during an inspection, and not just the passport itself.
How you prevent this
The core of the solution is simple to formulate, though execution requires attention: establish for each data point in the passport which existing source it comes from, and ensure that a change in that source also leads to a change in the passport. This requires one process owner who oversees both documentation flows, instead of a passport that is put together by a different department without sight of the technical documentation.
When working with a software supplier to enter or maintain the passport, it is worthwhile to explicitly discuss how changes in your existing product documentation are communicated and processed. how we collect and maintain data shows what that process looks like at prodpas.eu. If you would first like to assess where your company stands on this point, then the free product scan with a few questions provides an initial indication, without this saying anything about your specific legal position.
What this article does not answer
Whether your product documentation is currently sufficiently aligned with each other, and what consequences a difference between documents may have in your situation, cannot be answered in general terms. For that, your own product file is needed, and possibly the opinion of a lawyer or the competent supervisory authority.
Would you like to identify this type of error early before it ends up in your documentation? Take the free quick scan or browse through the topics in frequently asked questions about the digital product passport to see which situation comes closest to yours.