A digital product passport is compiled once, but remains accessible for ten years via the QR data carrier on the product. During that period, many things can change: a component is replaced by a different supplier, a repair instruction is updated, or new information is added about origin or composition. The costs to make those changes depend on three things: how often something changes, how significant the change is, and whether your service provider includes updates as standard or charges separately.
This is not about the one-time startup costs of a passport, but about what happens afterwards when the underlying data change. For the first question — what does it cost to start — there is already a separate answer elsewhere on this site. This article is about what comes next: keeping it up to date.
Why a passport is not static
The idea behind the digital product passport is that the information is correct as long as the product is in circulation. A passport that was correct at publication but was never updated afterwards no longer fulfils its purpose the moment reality changes. Think of a manufacturer switching battery suppliers, or an importer updating a repair manual. The obligation to keep information correct lies with the provider of the passport — usually the manufacturer or importer — and not with the platform that hosts the passport.
Whether, and how often, this happens in practice varies greatly by product category. A simple product with few components changes less often than, for example, ICT equipment with software components that are regularly updated. Those who want to assess how this works out for their own range can see in a few questions which situation applies.
What determines the costs of updating
The most important factor is the nature of the change. Correcting a typo or updating a phone number is different from adding a new component with its own certification. Some service providers make this distinction: small, administrative adjustments fall under regular management, while structural changes — a new supplier, different composition, modified repair process — are treated as separate assignments.
A second factor is the number of products the change applies to. If a component that is in a hundred different models changes, the impact is greater than if a change affects only one product variant. Service providers who work with passports per product line can often process this more efficiently than when each passport is built separately.
A third factor is who supplies the data and in what form. If the change comes in as a complete, structured file, processing is simpler than when the information must be manually extracted from emails or loose documents. This relates to how the passport is compiled in practice; more on this is explained in the article about where the information for the passport comes from.
What is and is not included as standard
Whether updates are included in a subscription or charged separately varies by service provider and package. Some structures charge a fixed amount for ten years of hosting including a limited number of changes per year; others work with a base price plus a fee per adjustment. Neither is inherently better — it depends on how often your products actually change and how much cost predictability you want.
A current overview of what is included in elektropas.com's rates can be found on the pricing page. For companies managing multiple product categories, it is often useful to discuss in advance how changes are to be submitted, so that processing does not have to be figured out anew each time.
What is not yet settled
The delegated acts that specify precisely which data are mandatory for each product category and how often they must be current are expected from 2027 onwards within the ESPR work plan. As long as the act for your category has not been published, it cannot be said with certainty how strictly the obligation to update will be applied in practice. For the legal obligation itself — what must be kept on record by law and within what timeframe — the official text on EUR-Lex or the competent supervisory authority is the appropriate source; this article describes only what determines the cost of updating in practice.
Anyone wanting a broader overview of how the passport features in day-to-day business operations will find that in the knowledge base with explanations per subject.
Would you like to know how this works out for your own products? The free quick-scan provides an initial indication in a few minutes, without requiring an account.