The most common mistake with the QR code of the digital product passport is that the code is on the product, but does not stay with the product throughout its entire lifespan. The code comes loose, fades, is on packaging that gets thrown away, or points to a document that is no longer being updated. This means the passport exists, but at the moment someone needs it, it can no longer be found or is no longer current.
This mistake usually does not arise from carelessness, but from a wrong assumption: that the QR code is a one-time action, comparable to a CE sticker. However, the regulation looks at the data carrier over the entire lifespan of the product, and that requires different choices than a drop of glue and a sheet of stickers.
Why the QR code is more than a sticker
The QR code is the data carrier: the physical reference to the digital passport. The regulation sets requirements for that carrier, such as readability and durability for the duration that the product is in use. This is a different premise than packaging labels, which often lose their function after purchase. A product passport must still be accessible after years of use, during a repair, upon resale or during recycling. More information on how the link between code and data works can be found in the explanation of how the data is created.
The three variants of the same mistake
In practice, the mistake appears in a few fixed forms. The first is physical: the code is on a sticker that comes loose, on a component that gets replaced, or on packaging that the end user throws away. The second is technical: the code points to a fixed document, for example a PDF on your own website, instead of pointing to an environment that can be updated if data changes. The third is organizational: no one in the company is designated as responsible for the code, so when a new supplier, a model change or a website move occurs, the link dies without anyone noticing.
All these variants lead to the same result: a product with a passport that exists on paper, but in practice is not accessible. For an installation company, an office with equipment or an importer of white goods, this is a risk that only becomes visible at the moment someone — a customer, a recycler, a supervisor — actually scans the code.
What supervisors consult
The regulation distinguishes between the obligation to have a passport and the obligation to actually keep that passport accessible. Supervisors in the Netherlands and elsewhere in the EU look at inspections for the findability and timeliness of the data behind the code, not just at the presence of a sticker. How that supervision is arranged in detail is not yet fully determined; the delegated acts per product group are expected from 2027 onwards. What is already clear: a code that points to outdated or inaccessible data does the same in practice as having no code at all.
How to prevent this in practice
The core of the solution does not lie in a better sticker, but in two choices that are made beforehand. First: the code should be on a component that follows the lifespan of the product, not on packaging or a separate component. Second: the code points to an environment that you or your supplier can update without the code itself needing to change. That is precisely why companies have the passport hosted instead of managing a document themselves — the code remains the same, the data behind it can stay current.
In addition, it helps to determine in advance who in your organization is responsible for the code: who reports it if a supplier changes, who checks whether the link still works, and who is the point of contact if a customer or supervisor asks questions. Without that agreement, the mistake happens automatically, even in companies that initially attached the code properly.
Whether your products already fall under this obligation and when depends on the product group and is not yet fixed for everyone. In a few questions you can see where your products stand now, and in the knowledge base by topic you will find the location in the official text and a brief answer to each question. For your own situation, and for questions about liability if the code does fail, a lawyer or the competent supervisory authority remains the appropriate point of contact.
Would you like to first see if this applies to your business before investing time in developing it? Do the free quick-scan or browse through the topics — both are without obligation and give an immediate indication.