If the data in the digital product passport is incorrect, this is a different situation than when there is no passport at all. Think of a material composition that does not match the actual product, a certificate that has expired without the passport being updated, or a repair guide that belongs to an older model. The regulation focuses not only on whether a passport exists, but also on the accuracy of what it contains. Incorrect data can thus raise questions, even if there is formally a passport.
What happens next depends on several factors: what type of error it is, who caused the error, and how it is responded to once it comes to light. The regulation itself does not yet describe in detail how supervisory authorities will act in each situation; that is something the competent supervisory authority will make statements about, not this article. What is clear, however, is that a passport that is not accurate in content is something different from a passport that simply does not exist, and that both situations are assessed in their own way.
Why this is a different situation than not having a passport
If a passport is missing, the question is mainly whether the obligation has been met. If the data is incorrect, the question goes deeper: is the information that a buyer, an installer or a recycler relies on reliable? The purpose of the passport is that everyone in the chain — from the project furnisher to the party that will eventually dismantle the furniture for recycling — can rely on what is stated in it. Data that is incorrect undermines that objective in a different way than an empty passport. That is also the reason why supervision is not limited to the question "is there something", but also looks at "is what is stated correct".
Who is responsible for accuracy
The data in the passport come from the manufacturer or the importer; they are the party that supplies the facts about the product. Whoever subsequently compiles and hosts the passport — this could be a service provider, as is the case with furnipas.eu — processes that data, but the accuracy of the underlying information lies with whoever has supplied it. This distinction is important when a company works with multiple parties: a software supplier, a designated provider, and the manufacturer itself. Who performs which role and who enters which data is something that can be clarified in advance, for example in the contract with a software supplier or platform.
To see which data are relevant for your type of furniture and where the most confusion arises, you can read through the topics by situation. For each obligation, it describes which information is relevant and where the source is located in the official text.
What may follow in practice
A supervisory authority that checks data in a passport and finds a discrepancy can ask questions about it to the party responsible for the data. The exact process, the timelines involved and the possible outcomes are not detailed until the implementing rules for furniture have been published. What is clear, however, is that an error that is identified and corrected in time is a different situation from an error that only comes to light during an inspection. Companies that review their data periodically — for example when there is a change in a product line, a raw material supplier or a certificate — reduce the risk of a passport containing incorrect information for an extended period.
The relationship with existing rules
This question also relates to rules that existed before the furniture product passport was introduced. Product safety rules already impose requirements on the information a manufacturer provides about a product, and a passport with inaccurate data can therefore become relevant for supervision in multiple ways. The question of who may view and edit which data also relates to how data is stored and protected; you can read more about this on how data is stored and who can access it. For the precise interaction with rules that apply specifically to your product, a lawyer or the competent supervisory authority is the appropriate party to consult; this article only describes the main lines.
How you prevent this in practice
Most inaccuracies in a passport do not arise from unwillingness, but from data that has not been updated after a change in the product or process. By determining in advance who supplies which data, how often it is checked and who the passport provider is, you prevent a large part of these situations. If you are unsure whether your current working method provides sufficient guidance, you can see in a few questions where your company currently stands. The frequently asked questions also provide immediate clarity on a number of points, for example about who may provide which data; you can find these in the overview with short answers.
If after reading this article you need a concrete picture of your own situation, the free quick-scan is a logical next step, or you can read further in the knowledge base for the topics that specifically apply to your products.