You can prepare part of the digital product passport yourself: collecting product data, determining your role in the supply chain and putting existing technical documentation in order are activities you can do with your own staff. Where it becomes more difficult is with the technical side: the passport must be offered in a specified format, linked to a QR carrier, and must remain accessible for years in accordance with the regulation. The latter requires a system designed for this purpose, not a loose file on your own server.
The regulation itself does not prescribe who must technically host the passport. However, it does require that the information remains available and that the data is traceable to the source. For a company operating a few product types, this may be manageable with its own IT department. For a company with many variants, multiple suppliers or annual model changes, keeping track of that traceability quickly becomes an ongoing task rather than a one-off project.
What you can prepare yourself
Collecting the source data is work that no one else can do for you: only you, your manufacturer or your importer knows which materials have been used, which repair instructions apply and which certificates belong to a product. Determining who in your supply chain acts as a provider within the meaning of the regulation is also something you must look at yourself, possibly with a lawyer if the division of roles is not obvious. Anyone who tackles this preparation in a structured way will have less to correct later. The knowledge base with explanations per subject shows exactly where you are in that process.
Where the technology requires a specialist
Once the data has been collected, something must be done with it that goes beyond an Excel file: a structured format, a unique QR code per product or product group, and an environment that remains accessible for ten years, even if your own website changes or a supplier disappears. The latter is precisely where building it yourself becomes risky: an internal system that works now must still work ten years from now, with the same traceability to the source. Companies that want to set this up themselves often do not underestimate the first version, but the maintenance afterwards. How such a link works in practice is explained on the page how the data is processed into a passport.
The trade-off: do it yourself or outsource
Whether managing it yourself is sensible depends on a few practical things: how many product types you carry, how often specifications change, whether you already have a system that can store data for a long time, and whether you have the knowledge in-house to keep up with changes in the regulation. For a small range with little change, managing it yourself is manageable. For a broader range, or when multiple departments are involved in the data, the risk of a missed update outweighs the time outsourcing takes. A brief overview of where your situation stands is available through the product scan that provides an indication in a few questions.
What is not yet settled
The delegated acts that set the technical details per product category are expected from 2027 onwards and are not all published yet. This means that the exact requirements for the format, and therefore also how much you can build yourself without having to adjust it afterwards, may still change. Anyone collecting data now would do well to use a setup that remains adaptable rather than definitive. For the current status per sub-category, the official text on EUR-Lex is the place to find it; questions about your own situation are best addressed to a lawyer or the relevant supervisory authority, not to a general article.
Would you first like to see which part of the process is mainly preparation for you, and which part requires a system? The free quick-scan gives you an initial indication of that in a couple of minutes, and in the answers to frequently asked questions you will find more about what does and does not fall under your own responsibility.