What documents must you be able to show the supervisor?
When a supervisor asks questions about the digital product passport, it essentially comes down to a few types of documents: the technical documentation of the product, the declaration of conformity, data on the origin and composition of materials, information on repair and spare parts, and the records showing who in the supply chain has provided which data. None of these documents stands alone. Together they must demonstrate that what appears in the passport is correct and can be traced back to a source.
The latter is the detail that matters most in supervision, and that is often underestimated. A passport that looks complete but for which nobody can any longer point out where a figure or a claim comes from, tells a different story for a supervisor than a passport where every piece of data can be traced back to a document, a supplier or a measurement. The regulation itself deals with the content of the passport; supervision and enforcement in practice are mainly about whether you can substantiate that content.
Traceability as a red thread
Traceability means concretely: for every piece of data in the passport you must be able to point out who provided it, on what basis, and when. This applies equally to an importer who passes on data from a manufacturer outside the EU as it does to a manufacturer who documents the technology itself. For some of the data, this amounts to keeping the underlying certificates and test reports; for other data it is about correspondence with a supplier showing that a statement has been confirmed.
This idea is not new. It aligns with how supervision already works around product safety and CE marking: a declaration alone is not enough, the substantiation must be retained and be able to be shown on request. The digital product passport adds a layer to this, because the data will then also need to remain accessible digitally and for a longer period via the QR data carrier. How we arrange this traceability at elektropas.com is described on the page on how the information is created.
Who exactly supervises
For which subcategory of electronics and ICT which authority in the Netherlands is competent is not yet fixed for every product. This is related to the delegated acts that the European Commission publishes per product group; once such an act is in place, it will also become clearer how supervision is organised. Until that time, it is useful to know that market surveillance in the Netherlands is usually divided among a limited number of authorities, each for their own product area. For the precise competence and working method of the supervisor for your product group, the supervisor itself is the appropriate source, not a general explanation like this one.
What this means for what you already have in place
Many companies already have some of this documentation, because they also need it for the General Product Safety Regulation or for CE marking. That is a good starting point: the passport does not ask for new administration alongside the existing one, but for the same substantiation, clearly linked to the product and accessible for a longer period. Where things often go wrong is not in the absence of documents, but in the absence of a clear link between a piece of data in the passport and the document on which it is based. An overview of the different subjects that come together here can be found in the knowledge base per situation.
Start with what you can already substantiate
For most companies, it is feasible to start with the documents you already have, and from there examine which data are still missing a clear source. This prevents you from starting the product passport from scratch. If you are uncertain which documents are relevant for your product, it helps to compare your question with what other companies in the same situation encounter; those answers are collected on the frequently asked questions page.
Would you like a quick indication for your own situation without having to go through all the regulations? Then take the free quick-scan via a few questions that show where you stand, or continue reading in the knowledge base which step should be addressed first for your company.