Yes, you can do part of the work on a digital product passport yourself. Gathering product data, designating who within your company is responsible, and keeping track of changes to a product are tasks that your own organization can handle well. Building the passport itself technically, linking it with a QR data carrier that meets the specified requirements, and keeping that information available for ten years are aspects for which most companies bring in a specialized party.
The reason for this is not that it is impossible to do it yourself. It is an investment that may not be proportionate for every company relative to the number of products it brings to market. Below you can see concretely which steps you can take yourself and which steps require more than a spreadsheet and a free QR generator.
What exactly does arranging it yourself entail?
A digital product passport is more than a QR code on a label. Behind that code there should be a dataset that is constructed in a fixed, traceable manner, that remains accessible for ten years, and that stays up to date if anything changes about the product. Arranging it yourself means that your company not only supplies the data, but also takes care of the hosting, the data structure, the languages in which the passport is available, and the maintenance of it over a period of ten years. In how we build passports from your source data you can see which steps are involved when a platform does this for you.
Which aspects can you handle yourself?
Your own organization knows the data about your product best. Think of material composition, origin of components, repair instructions and information about recycling. Gathering and structuring that data is work that can be done well internally, although it does require discipline: the data must remain current as long as the product is on the market and remain available for years afterwards.
Designating the party within the chain responsible for the passport is also something you determine yourself. That is an organizational choice, not a technical one. Who exactly fulfils that role and what is involved varies by situation and by link in the chain; the knowledge base with explanation per subject goes into more detail on that.
Where does arranging it yourself run into limits?
The technical side is where arranging it yourself becomes more complicated. The QR data carrier must comply with a specified standard, so that every market participant and supervisory authority in the European Union can read the data in the same way. Building a system yourself that complies with that standard is technically possible, but requires knowledge of data models that are still very much in development: the delegated act that sets out the precise requirements has not yet been published.
In addition, there is the hosting obligation of ten years. That means the information must also be available if your company uses a different system, switches software providers, or stops a product line. For many companies, that is a reason to place this long-running obligation with a platform rather than with an internal IT system that may no longer exist in ten years.
What factors into the choice?
Whether arranging it yourself is feasible for your company depends on factors such as the number of products, the frequency with which they change, internal IT capacity and the extent to which you already keep data structured. A company that already has a product information system is in a different position than a company that still has data in loose documents.
This assessment is not the same for every company, and there is no general answer. What you can do is: map out which components apply to your company and how much work is involved. With a few questions see which components apply to you you get a first, non-binding picture.
Where you can find this
The regulation itself says nothing about whether a company must build the product passport itself or may outsource it; that is a choice that lies with the provider. What the rules do lay down are the requirements that the end result must meet. For the precise location of those requirements in the official text, and for answers to frequently asked questions, you can consult the frequently asked questions about this obligation.
Are you unsure whether managing it yourself for your situation is feasible, or do you want to first see exactly how much work is involved? Take the free quick-scan or browse through the topics in the knowledge bank — both give a first, concrete picture without obligation.