When purchasing a product from a manufacturer or supplier, you generally need four types of documents for the digital product passport: data on materials and composition, technical documentation and declarations of conformity, a unique product identification such as an article or batch number, and proof of origin such as an invoice or certificate of origin. The detail most often overlooked is that responsibility for the accuracy of that data does not automatically remain with the supplier once you place the product on the market under your own name.
This last point deserves explanation, as it determines in practice how much work requesting documents costs. The regulation distinguishes different roles in the supply chain, and whoever acts as a manufacturer or importer bears their own responsibility for the data in the passport, even when that data originally comes from a supplier. A supplier who provides only a technical data sheet therefore does not automatically cover everything that is needed.
Which documents you generally request
The basis is material information: what substances and components the product consists of, and whether there are substances that must be reported separately. In addition, technical documentation is needed, such as test reports or a declaration of conformity demonstrating that the product meets the applicable requirements. A third document is product identification: an article number, batch code or other identifier linking the passport to the correct item or series. Finally, proof of origin is often needed, such as an invoice, receipt confirmation or certificate, especially when the product originates from outside the European Union.
Which of these documents are exactly mandatory and in what form varies by product group. For some products, the emphasis is on repair and maintenance information, for others on recycling data or chemical composition. Those wishing to see how this applies to a specific product will find in the knowledge base per product group clarified an overview per situation.
Why this detail is so often missed
In procurement, a supplier document is often considered complete once it has been received and stored. The point where things regularly go wrong is that a document sufficient for the supplier's own administration does not automatically align with what the passport requires. A test report may for example be outdated, a declaration of conformity may concern a different product version, or data may have been provided in a language or format not traceable to the specific item you are selling. Because responsibility for the accuracy of the passport remains with the provider, translating these documents to suit your own situation is something a lawyer or the competent supervisory authority can be consulted about.
Recording which party supplies which document
Because the documentation burden is shared in practice among manufacturer, importer and possibly a distributor, it is worthwhile to record when concluding or renewing a supply contract which party supplies which document, in what form and at what time. This prevents a passport from being found to lack a test report or identification code only when it is being drawn up. For companies arranging this for the first time, it is useful to determine in advance which arrangements are standard in a purchase contract, so this does not need to be figured out again for each order.
If the supplier is located outside the European Union
When purchasing from outside the Union, there is often an extra step involved: the data must not only be complete, but also demonstrably match what is actually imported. Customs documents, a certificate of origin and a clear link between shipment and product identification then play a larger role than when purchasing within the Union. Which documents are precisely required depends on the product group and country of origin, and this is something the competent supervisory authority or a lawyer can clarify for your specific situation.
To see how complete your own documentation already is in relation to what is required for your product group, you can go through the free product scan with a few short questions. If you first want to know how prodpas.eu processes the supplied data into a passport, you can read that on the page where the information in the passport comes from. And for any questions that remain after reading, an overview is available in the frequently asked questions about the digital product passport.