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I found an error in the product passport what now

You correct an error by updating the data, not by creating a new product passport

You correct an error in a published product passport by correcting the underlying data, after which that correction becomes available via the existing QR data carrier. The ESPR assumes one passport per product that remains linked to a unique identification; the passport is intended as something that stays current and accessible throughout the product's lifetime, not as a snapshot that you replace with something new when an error occurs. This means that the link or QR code that appears on the product or packaging remains the same — only the content behind it is adjusted.

What counts as "an error" and what does not

This approach applies to errors in the content of the passport itself: an incorrectly entered value, an incorrect property, an incorrect link to a product group, or a reference to an incorrect document. It therefore concerns correction of data that already falls under the regular update obligation — how often must I update the data in the product passport? states that a passport is not a fixed document but something that is maintained throughout the product's lifetime. An error correction is in that sense nothing other than an interim update, only then as a result of a discovered inaccuracy rather than a scheduled moment.

What does not fall under this: errors that arise because a measurement or calculation method was incorrectly applied in a way that structurally affects the outcome, for example in energy consumption or repairability. Article 39 of the ESPR concerns the test, measurement and calculation methods that must be used for a product group, and if the error lies there — that is, in the method, not in the input — the correction is different: then measurement or calculation must be performed again according to the prescribed method, as described in according to which method should I measure the values for the passport?. Nor does an error that points to intentional manipulation of data — to make a product score better than it actually is — fall under a regular correction. Article 40 of the ESPR prohibits circumvention and degradation of performance that affects compliance with requirements; if an error is actually a disguised attempt to avoid stricter requirements, it falls into a different regime than a simple data correction.

Which date here is fixed and which is not yet

No delegated act has yet been published for electronics and ICT equipment that specifies a procedure for error correction in the passport. The ESPR itself, in Article 9 and Article 10, does describe the basic requirements that a digital product passport must meet — including that data must be current, correct and accessible — but the elaboration per product group, with any specific rules on how and how quickly an error is corrected, follows from the delegated act that is still to come for electronics. Until that act is published, the general principle from the ESPR applies: the passport must contain the correct data, and data that is not correct should be corrected. Once the delegated act for electronics and ICT is known, this will be supplemented with how that procedure becomes more specific, if applicable.

How to approach this in practice

Anyone who discovers an error should start by determining where the error lies precisely: in a single data field (for example an incorrectly entered number or an incorrect material declaration), or in the underlying measurement or calculation. In case of a data error, the correction is usually straightforward: the correct value is supplied and processed, after which it is disclosed via the same QR data carrier — the reader who scans the product will then automatically see the corrected version, without a new code needing to be placed on the product.

If the error lies deeper, for example because a repairability score was calculated incorrectly or a mandatory entry on critical raw materials was missing, it is advisable to first check which data is precisely mandatory for that product group. What data goes into the product passport for electronics? and which data must I fill in exactly for my type of device provide an overview, so that the correction not only resolves the reported issue but also immediately verifies whether the rest of the passport for that product group is complete. In case of doubt whether a particular piece of data is commercially sensitive and therefore cannot simply be corrected publicly, must I disclose commercially sensitive data about my electronics to the public? is a logical next step, and in case of doubt as to who will be allowed to see the corrected data later, it helps who may view which data from the product passport?. After that, the correction is processed and, if the platform records it, the date and reason for the change is documented — this also makes the passport traceable afterwards.

The legal basis: articles 9, 10, 39 and 40 of the ESPR

Article 9 of the ESPR describes the digital product passport as a whole; article 10 sets the requirements that the data in it must meet — including accuracy and accessibility for the duration of the product's life. Article 39 requires that values be determined according to established test, measurement and calculation methods, which is relevant as soon as an error lies not in the input but in the method used. Article 40 focuses on preventing circumvention and deterioration of performance, and thus marks the distinction between a genuine error and a data representation that deliberately gives a false picture.

What to do now

Anyone who discovers an error in a published passport first determines whether it is an incorrectly entered piece of data or an error in the measurement or calculation method, then corrects the data at the source, and allows that correction to flow through to the existing QR data carrier so that no new code is needed. Once the delegated act for electronics and ICT is published, it will be supplemented here as to whether a more specific error correction procedure applies.

What you must concretely do

What is expected of you

An error in a published passport is not an exceptional situation about which the ESPR says nothing — articles 9 and 10 of Regulation (EU) 2024/1781 assume a passport that displays the current, accurate data of the product. An inaccuracy that remains is therefore essentially a passport that does not meet the basic requirements. What that means in practice breaks down into a few sub-obligations.

Recognizing that it is an error, not a modification

Not every adjustment to a passport is a correction. If a production change produces a different value (for example, adjusted energy consumption following a technical modification), that is an update of the data — not a restoration of an error. For a company with 10 to 100 employees, this distinction is particularly relevant for internal record-keeping: an error correction and a product modification should in practice receive a different recording trail, even though the reader of the passport only sees the end result. How often data must be updated anyway is separate from an error; that can be read on the page about how current the data in the product passport must be.

Restoring based on the correct source value

Article 39 of the ESPR links the data in the passport to established test, measurement and calculation methods. In practice, correcting an error means: going back to the underlying measurement or calculation, determining what went wrong (incorrect test setup, incorrect unit, incorrect product linked to the passport) and deriving the new value according to the same method by which it should originally have been determined. For a mid-sized company, this is usually not a legal step but a technical one: the quality department or external testing party provides the correct value, and that value replaces the erroneous one. Which method applies to which value is described on the page about the method by which values for the passport are measured.

Ensure that the QR data carrier continues to point to the restored version

The passport is unlocked via a data carrier (typically a QR code) linked to the product. Correcting an error must not result in a new, separate data carrier alongside the old one: that would create confusion about which passport belongs to which unit. In practice, this amounts to updating the content under the existing link, so that the same QR code after correction points to the correct data. For a company working through a platform like this, this is a technical action performed by the platform; for the company itself, it is relevant to know which data precisely belongs here, as explained on the page about which data go into the digital product passport.

Preventing the error from indicating a structural problem

Article 40 of the ESPR addresses the prevention of circumvention and degradation of performance. An incidental error in a passport is not in itself circumvention, but a pattern of repeated, favourably skewed "errors" — for example, consistently slightly too positive energy values — can fall into that category. For a company, this means that the distinction between a one-off, demonstrable mistake and a recurring deviation pattern is important to be able to make, and that the substantiation of each correction should be traceable.

Where things go wrong in practice

A passport is manually adjusted without it being established who made the change and why — with the result that half a year later no one can reconstruct whether the current value is the corrected or the original one.

An error is corrected in the internal ERP system, but not transferred to the published passport, because the link between production data and passport is not automatic.

An importer discovers that a supplier has provided an incorrect value (for example, about a critical raw material that is or is not present) and corrects the passport, but does not document that the error originated with the supplier — which later creates confusion if questions arise about it. See also the explanation about which critical raw materials must be reported in the passport.

An error is corrected in the main language of the passport, but not in the translated versions, resulting in temporarily contradictory information in circulation. This is particularly an issue for companies working with multiple market versions; background information on this is on the page about providing passport data in multiple languages.

A correction to a repairability score is made without re-documenting the underlying calculation, making it impossible to trace whether the new score was determined in the same manner as prescribed. More on that calculation is on the page about how the repairability score of a device is determined.

What you can document

  • An internal change log per passport: date of error discovery, nature of the error, original value, corrected value, and who made the correction.
  • The underlying measurement or test report substantiating the new, correct value, including reference to the method used.
  • Correspondence with a supplier or manufacturer, if the error originated there, so that the source of the deviation remains traceable.
  • Confirmation that the correction has been made in all language versions of the passport that are in circulation for the product.
  • An internal check as to whether the error was a one-off mistake or part of a broader pattern, with a brief substantiation of that conclusion.
  • A template for error reporting and correction, so that each correction is documented in the same manner and is not dependent on who happens to discover and resolve the error.

This is not legal advice. This page provides general information about the regulations that this platform covers. We are not familiar with your situation. If you are in doubt about your own case, consult a lawyer or the competent supervisory authority.

Written with AI based on the sources above, checked by a human on 2026-09-05. Is something not correct? Let us know — corrections take priority.