The most common mistake when collecting data for the digital product passport is that companies wait until just before a deadline, and then leave it to one person or department. The information that must go into a passport — about materials, origin, repair, recycling options — in practice comes from procurement, engineering, quality assurance and sometimes from the supplier itself. If this is only collected once the passport must be made, companies often discover that the data is scattered across different systems, people who are no longer employed, or suppliers who are not used to answering these questions.
The solution is not to rush, but to start early and assign the task to multiple people who each know their own part. This prevents one employee from having to reconstruct data under time pressure that was actually stored somewhere already, or worse: filling in data that is incorrect because the correct source could no longer be traced.
Where things often go wrong
In practice we see three recurring patterns. The first is that a company thinks the passport is a matter of filling in a form, while the underlying data — origin of materials, composition, repair data — is not recorded centrally anywhere. The second pattern is that responsibility is assigned to one department, usually procurement or quality, while engineering or the importer actually has the data on origin and composition. The third pattern is that companies rely on supplier data without checking whether that data is current and complete.
None of these errors is dramatic at the time itself. They only become visible when the passport actually has to be compiled and it turns out that pieces are missing, contradictory, or cannot be traced back to a source. That then costs time that is no longer available at that point.
Why this mistake occurs so often
The regulation and the delegated acts per product category have not yet been published for every sub-category; the ESPR work programme provides for delegated acts from 2027 onwards. This means that for many companies it does not yet feel urgent to organise data now. This is understandable, but the risk is not in the date of the obligation — it is in the question of whether the data will still be there by that time. Staff changes, system changes and suppliers that change name or ownership mean that data that is easy to trace now may not necessarily be so in a few years' time.
How to prevent it
It starts with an overview of what you already know and what you still need to ask. For most electronics and ICT products, this is about data on materials and composition, origin, repair and maintenance options, and end of life. If you create this overview per product group, you will often see that some of it is already stored somewhere — in procurement, in engineering, or with the manufacturer abroad — and that the main thing missing is bringing it together.
Who does what
It helps to designate one contact person per data category, rather than assigning the entire task to one department. Someone from engineering knows the material composition, someone from procurement knows the supplier and the contractual agreements, and someone from quality assurance often knows where existing certificates and test reports are stored. This also aligns with the broader discussion with a software supplier or sub-supplier about what data they can provide and in what form.
Starting early pays off
Because the exact obligations per product category are not yet fixed, there is no reason to create a complete passport now. There is reason to already know where the underlying data is located, so that compiling the passport later is a matter of organising rather than reconstructing. worked out per subject what is relevant for your situation provides an overview of which data per product category are usually requested.
What this is not
This article describes a common pattern, not an assessment of your specific situation. Whether, and when, your company falls under a delegated act, and which data is then precisely required, depends on the product category and the text as it is ultimately published. For your own situation, consult the official text or a legal professional.
Would you first like to see where your company stands for this obligation, without spending time on it right away? get an indication in a few questions shows which data are relevant for your product group. More background on how we compile that information is described on the page about our working method, and frequently asked questions about the process can be found collected on one page.