What is the most common mistake when entering a digital product passport?
The most common mistake companies make when introducing a digital product passport is not in the technology or the legal text. The problem starts at the foundation: no one within the organization owns the data that must go into the passport. Procurement has the supplier list, quality has the test reports, and the technical department knows which components actually end up in the product. Without someone bringing that together, the implementation stalls at gathering information that was already somewhere in the company.
The result is predictable: half a year of back-and-forth emails, data that contradicts itself, and ultimately a passport compiled based on the information that happened to come to light fastest. That is not necessarily incorrect, but it is also not the most solid foundation for something that must remain online for ten years.
Why this mistake occurs so often
The regulation for digital product passports places responsibility with the manufacturer or importer, but says nothing about how a company organizes that internally. At larger enterprises, product information is often scattered across multiple departments and systems that were never connected for this purpose. At smaller companies, sometimes a system is lacking altogether, and knowledge sits in the heads of a few people. In both cases, the first instinct is to pass the question to whoever happens to be closest to the subject, usually someone in procurement or quality who then gets a task without the mandate to direct other departments.
What goes wrong when no one owns the data
Without a clear owner, three problems emerge that reinforce each other. First, gathering data takes longer than necessary, because every department waits for another to take the first step. Second, there is no one to check whether the submitted information is correct and up to date, so errors are only noticed after the passport has been published. Third, there is no fixed point of contact for the party that technically compiles the passport, which makes the conversation with a software supplier or service provider unnecessarily cumbersome.
This is also the moment when companies realize that a product passport is not a one-time document, but a data stream that must remain accurate as long as the product is on the market. Those who have not arranged this beforehand usually only discover it when making the first change: a new supplier, an adjusted composition, or a correction to previously entered data.
How you avoid the mistake
The core of the solution is simple to state, even if implementation takes time: designate one person or a small team responsible for the completeness and accuracy of the product data, with sufficient mandate to ask other departments for submission. This responsibility does not have to lie with a lawyer or IT specialist; in practice it often works best with someone who already has an overview of the product, such as a product manager or someone from quality assurance.
It helps to map out beforehand which data is needed and where that data is already recorded, before you discuss the technical implementation with a supplier or platform. With a few questions that will give you an initial indication you quickly get insight into where you stand for your own products, without having to figure everything out first.
What this means for collaboration with your software supplier
Once ownership is established internally, the conversation with a software supplier or platform runs considerably more smoothly. You can then ask concrete questions about which data is taken over, how changes are made, and who remains responsible for its accuracy. That responsibility always remains with the manufacturer or importer, even if technical processing is outsourced. In the knowledge bank by subject you will find the background to this division of responsibilities, including the location in the official text.
It is also worth previewing in advance how a platform handles the data you provide, especially when it comes to business-sensitive information. On the page about how data is stored and secured you can read what to pay attention to.
Finally
The most common mistake when implementing a digital product passport is not in complicated regulations, but in a simple organisational step that is skipped: appointing someone who collects the data and keeps it up to date. For the question of which obligations precisely apply to your products, the official text or a lawyer remains the right point of contact. Do you want to first get an idea of where you stand? Then do the free quick-scan or read the other topics in the knowledge base.