When a supervisor asks for the furniture passport of a product, it is rarely only about the QR code that the customer scans. The supervisor also looks at what is behind it: who provided the data, on what basis, and whether the passport remains accessible for ten years as the regulation requires. The most important documents are therefore not the passport itself, but the evidence supporting it.
Think of the documentation with which you can show who within your company is responsible for the passport, the agreements with your software supplier or hosting partner regarding availability, and the origin of the product data contained in the passport. That last detail is most important in supervision: a passport that looks good but for which no one can demonstrate where the figures come from is a different story for a supervisor than a passport with a clear paper trail behind it.
The difference between the passport and the supporting evidence
The passport that a customer sees via the QR code is the outside: materials, origin, repair information, and what the regulation further requires. Supervision usually focuses not only on that outside, but also on the inside: can the company demonstrate that the data is correct and that it is kept up to date once the product changes? That supporting evidence usually consists of internal documents that are not intended for the end customer, but may be relevant to the supervisor.
This includes, for example, supplier specifications, internal product change logs, and correspondence showing when and by whom the passport was last updated. the knowledge base with explanations by topic goes into more detail here per situation, because the exact implementation differs depending on the type of company and the role in the chain.
Who provides which documents
The nature of the required documents is closely linked to the role a company has in the chain. A manufacturer must typically be able to show the technical evidence of the product, while an importer or distributor must rather be able to demonstrate that they have received the correct data from the manufacturer and passed it on unchanged. Anyone unsure which role applies to their own company will find more information about this elsewhere on this platform; that directly affects which documents are and are not needed.
Furthermore, proof of the appointment of the passport service provider is relevant: the agreement stipulating who hosted the passport, for what period, and under what conditions. This is not a mere formality, as the regulation requires accessibility for ten years, even if a company switches software suppliers or discontinues a product line.
Where these documents are best kept
Many companies keep this type of documentation scattered: a contract with the legal department, specifications with procurement, and changes in a separate Excel file with the product manager. That works until someone actually asks for it, and then the search work takes time that an inspection does not always allow. It is therefore practical to know in advance where which document is kept and who can refer to it before a possible request from a supervisor.
On the question of which data exactly must be collected and stored, there is still no fully developed practice; the delegated act that elaborates on this has not yet been published. What is certain is that in practice supervision looks more at traceability than at form: if a company can show where a piece of data comes from, that carries more weight than the exact format of a document.
What is not yet established
The regulation itself describes the purpose and main principles of the digital product passport, but the implementation details, including exactly which documents a supervisory authority may request and in what form, follow from delegated acts that are still in preparation. The division of competences between supervisory authorities in the Netherlands and in other EU Member States is also not yet fixed in detail. For your own situation, it is advisable to ask the competent supervisory authority about this or have it assessed by a lawyer.
If you want to see which documents are likely relevant for your own situation, you can get a first indication in a few questions. Curious how furnipas.eu obtains the underlying information and how it remains traceable, that is explained on the page on how the information is created. If your question is not among them, there is also an overview of frequently asked questions to read further.