can I modify data after the product passport has already been published

Changes are possible, but not retroactively just like that

Data in a published product passport can be adjusted, but the ESPR (Regulation (EU) 2024/1781) is based on a passport that follows the product throughout its entire lifecycle and whose information matches the current situation. This means that in practice, a change will more often involve supplementing or updating data than secretly rewriting what was there before. Article 9 of the ESPR requires that the data in the passport is accurate, complete and up-to-date, and that is an ongoing obligation — not something that only counts at the moment of publication.

Which data this applies to, and which does not

The distinction that matters here is between data that belongs to the product as it is placed on the market, and data that can change after sale. Think of repair history, changes of ownership, or additional certifications obtained later — that kind of information is meant to be supplemented as soon as it becomes available. Basic data that determines the identity of the product, such as the unique identification code by which the product is recognised, is fundamentally different: that code must continue to follow the product without change, because the entire recognition system is now built on that. Anyone wondering how that code is assigned in detail will find more information about it how each product receives a unique identification code. What this article does not address is the question of whether an error in the original conformity data can be corrected afterwards without consequences for the manufacturer's liability — that is a different question from the technical ability to adjust a data field, and the ESPR text does not provide a separate answer to it.

When this will apply is not yet determined

No delegated act has yet been published that specifically regulates how changes after publication should proceed for furniture. Articles 9, 10, 13 and 14 of the ESPR do establish the framework — that the passport must be up-to-date, that a register will be created, and that a web portal will be created to make data accessible — but the technical and operational details, including who may carry out a change and how it is recorded, still need to be worked out in product-specific regulations for furniture. Until that legislation is in place, there is no established date and no established procedure to point to. As soon as the delegated act for furniture is published, this will be updated here.

What this is likely to look like in practice

In practice, it is advisable to assume that a change to a passport does not mean that the old data disappears, but that a new, traceable version is created. This is consistent with Article 13, which provides for a register of digital product passports in which traceability plays a role. For those working with furnipas, this comes down to a few steps in practice. First: the data that needs to be adjusted is supplied in the same way as in the initial submission — via the manufacturer's or importer's own system. If the passport has already been linked to an ERP or inventory system, that link can also be used for later changes; how that works is described in linking the product passport to your own system. Subsequently, the change is processed in the hosted passport, without the QR code or the unique identification code on the product itself changing — after all, that remains the fixed reference to the passport, no matter how the content behind it is updated. What the manufacturer or importer can prepare for themselves here is an internal overview of which data has already been supplied and when, so that a later addition or correction can be submitted quickly and without fuss. This is also useful with regard to the period for which the passport must be maintained; more information on this is provided in how long a product passport must remain available.

The legal basis: Articles 9, 10, 13 and 14 of the ESPR

That a product passport must remain up to date follows from Article 9 of the ESPR, which describes the digital product passport as an instrument that makes data about a product accessible throughout its lifespan. Article 10 supplements this with the requirements that the passport must meet, including accuracy and completeness of the data. Article 13 introduces the register of digital product passports, which plays a role in making passports and the data within them traceable — which is relevant in the event of a later amendment. Article 14 regulates the web portal through which data from the passport is made accessible, which touches on the technical side of "amending": an adjustment in the underlying data must translate into what is visible through that portal. However, none of these articles yet provides a concrete procedure for amendments after publication specifically for furniture — that implementation is expected in a delegated act that does not yet exist.

Companies that already work with a product passport or are about to do so can find the most support by keeping their own source data well organised — so that a later addition or correction can be easily provided once a fixed procedure exists for it, and by monitoring when the delegated act for furniture is published, because that ultimately determines how amending will look like in practice.