The most common mistake companies make with the digital product passport is not in the technology and not in filling in data, but in the first step: determining which product group a product falls under exactly. Whoever classifies a product too hastily under the regulation that is best known, or under the regulation of the main product while a component falls separately under another one, builds a passport based on the wrong requirements. You often only notice this once the data has already been collected.
You avoid this mistake by basing the classification not on what a product is called or where it usually falls among comparable companies, but on the definition that appears in the regulation itself. A product can contain components that fall under a different product group than the whole, and an importer of a composite product can be subject to multiple regulations at the same time. Whoever only notices this when compiling the passport often has to redo part of the work.
Why this mistake occurs so often
Companies with multiple product groups usually encounter one regulation first, for example because it has been most in the news or because a supplier refers to it. This makes it tempting to assume that the rest of the assortment is treated the same way. In practice, product groups differ in what is exactly required, which data are requested and when the obligation takes effect. A furniture manufacturer who also supplies batteries with a product, or an importer of electronics with packaging made of textiles, can be subject to different regimes at the same time without this being immediately clear from the packaging or the trade name of the product.
A second reason is that the classification is often left to whoever happens to be compiling the passport, without it being established beforehand who in the company is responsible for that decision. As a result, the classification can vary per product line, while the underlying rules for the entire company should be the same.
What goes wrong if the classification is incorrect
If the product group has been incorrectly determined, data are collected based on the wrong requirements. This does not automatically mean that the passport is unusable, but it does mean that it may lack information that is required for the correct product group, or that it contains data that are not relevant for that group. Correcting this afterwards takes more time than getting the classification right beforehand, because data then have to be requested again from suppliers or internal departments.
Also, the question of which party in the chain bears which responsibility is linked to the product group. Whoever wants to understand that aspect will find background information on the different roles in the knowledge bank per topic, where roles and product groups are explained separately.
How you prevent the classification from being done too hastily
The classification becomes more reliable if you base it on the definition in the regulation itself, per component of the product, rather than on the product as a whole. For companies with a broad assortment, it is worthwhile to work through this in a structured way once rather than improvising anew per product line. You get a first indication by having a few questions show you where your products stand, so you can see whether more than one product group is involved before you start collecting data.
It is also wise to include the classification in the conversation with your software supplier, because the required fields differ per product group. Anyone who has doubts about this can read the common questions about it in the frequently asked questions about the product passport.
What to do if the classification has already been made
If the classification has been made and there is doubt as to whether it is correct, it is worthwhile to have it verified before the digital product passport is published, not after. For the precise situation of your company and your products, the text of the regulation itself, or the opinion of the competent supervisory authority or a legal professional, remains the appropriate source. Read more about how information on prodpas.eu is compiled and what it refers to on the page about our working method.
If you want to quickly see for yourself whether your products may fall under multiple product groups, do the free quick-scan or browse through the topics in the knowledge base. Both are free to access and provide initial guidance before you proceed with further development.