How often must I update the data in the product passport?

What you concretely have to do

What is expected of you

The ESPR regulates in Article 9 and Article 10 what must be included in the digital product passport and what technical requirements the passport must meet, but neither of these articles specifies a concrete deadline for how often the data must be updated. What does follow from it, however, is a number of practical obligations that together determine how 'current' a passport must remain in practice.

The data must match the product being sold

Article 9 of the ESPR links the passport to a specific product or product model. This means that the information in the passport must correspond with what is actually brought to the market. For a company with 10 to 100 employees, this means that every change in a product — a different type of foam, a different adhesive, an amended finish — must be visible to whoever manages the passport. Not because there is a fixed update frequency, but because the passport otherwise no longer matches the product it describes.

The passport must remain accessible throughout the product's lifespan

Article 10 sets requirements for the accessibility of the passport, also after the first sale. This concerns not only whether the link remains functional, but also whether the information behind it is still relevant for whoever consults the passport at that time — a fitter who wants to dismantle the furniture, a purchaser who wants to check the materials, or a recycler at the end of the product's life. Which parties exactly have access and to which data is described on who may view which data from the product passport.

Changes in the product often affect multiple sections of the passport at the same time

An adjustment that seems minor at first often has an impact on multiple fields of the passport. A different sheet material type affects not only the material registration, but possibly also the formaldehyde emission class and the recyclability percentage. For the material registration itself, it is relevant at what level it must be recorded; this is explained on must I record the material for each component of a piece of furniture. For the emission class, see how do I determine the formaldehyde emission class of a piece of furniture. A company that makes a product change only in its own technical documentation, but not in the passport, creates a discrepancy that will not be noticed automatically — until someone consults the passport and the data does not match.

Where things go wrong in practice

A supplier name or address changes, but the passport does not. When a supplier is taken over, a production location is relocated, or a subcontractor is changed, the passport is often forgotten because it does not seem like a 'product change'. Yet this type of information may be part of the passport.

A material composition changes due to a supplier switch, without anyone checking the passport for this. Procurement switches suppliers for, for example, foam or textiles, the technical specifications change slightly, but no one feeds this back to passport management. For upholstery and textiles this is a common issue, see how do I record data on textiles and upholstery in the product passport.

A repair or refurbishment is carried out, but not fed back to the passport. When a piece of furniture is repaired or refurbished and brought back onto the market, the question arises of whether and how this should be recorded in the passport. This is addressed on must I record repairs of a piece of furniture in the product passport.

The passport is filled in at launch and then not reviewed again. Particularly in companies where the passport is seen as a one-time compliance task rather than as an ongoing part of product management, there is a risk that the data gradually falls behind reality — without anyone actively deciding this.

Measurement methods or calculation rules change, while old values remain in the passport. When the method for determining a value changes — for example for the CO2 footprint or the recyclability percentage — it is not automatically clear whether existing product passports must be updated retroactively. Background information on the measurement method itself is available at according to which method must I measure the values for the product passport, and for the calculation of the recyclability percentage at how do I calculate the percentage of recyclable material of a piece of furniture.

What you can put in order now

• An internal process that links when a product change occurs to a control moment for the product passport. This can align with existing processes for engineering change or supplier management, so that the product passport is not treated as a separate item.
• An overview of who within the company is responsible for identifying changes that affect the product passport — procurement, product development, quality — and who actually carries out the amendment in the product passport.
• A file per product model with the underlying data on which the product passport is based, so that when a change occurs it is quickly visible which fields in the product passport are affected by it. This links to the question of which data exactly belong in the product passport, see which data are included in the product passport for furniture.
• A log of changes in the product passport, with date and reason, so that it is demonstrable when and why data have been amended.
• Agreements with suppliers on the communication of changes that are relevant for the product passport, for example in material composition or hazardous substances — relevant background material on this is available at which hazardous substances must I mention in the product passport of a piece of furniture.

Once the delegated act for furniture has been published, this will be supplemented or it will be clarified whether it includes a concrete deadline for updating.