can I correct an error in the product passport afterwards

What you must concretely do

What is expected of you

The ESPR describes how a digital product passport is structured and which data it should contain, but the regulation does not describe a separate "correction process" with steps that a manufacturer or importer must follow afterwards. What can indeed be derived from it comes from the requirements for the passport itself: the data must be correct, current and be made accessible in the proper way. In practice, this touches on three obligations.

The data in the passport must be correct and current

Article 9 and Article 10 of the ESPR describe what a digital product passport must contain and what technical requirements it must meet. From this it follows that a passport with an error — an incorrect alloy composition, a mixed-up certificate number, incorrect traceability — does not meet the purpose of the regulation. For a company of 10 to 100 employees, this means above all something organisational: there must be someone who knows which passport belongs to which batch or which piece, and who can detect an error as soon as it is reported. This requires a good link between production or inventory management and the passport, something for which the answer to can I link the product passport to my ERP or inventory system? goes into further.

The passport must remain findable via a fixed identification

Article 9 links the passport to a unique identification of the product. That identification is the key by which a passport is retrieved — even if its content changes. For practical purposes, this means that a correction generally does not bring a new identification with it: the passport remains accessible under the same code, only the data behind it changes. How that identification is constructed and assigned is described in how do I give each product a unique identification code?

The register must align with what is in the passport

Article 13 of the ESPR describes a register of digital product passports. If a passport is amended afterwards, it stands to reason that the data transmitted to that register must remain aligned with it — otherwise a discrepancy will arise between what the register displays and what the passport itself shows. What exactly must be included in that register and how it relates to the passport itself is explained at what is the register of digital product passports and what must I enter in it?

The QR code and the web portal must continue to refer to the correct, current version

Article 14 describes a web portal through which data from the product passport is accessible. A correction in the passport therefore only makes sense if the QR code on the product continues to refer to the same location, where the updated data can then be seen. There is no indication in the sources that an error in the passport means that a new QR code must be placed on the product — the code refers to an address, not to fixed content.

Where things go wrong in practice

Several situations recur regularly in practice.

An incorrect steel grade or quality class is listed, whereas the physical product is correct. This is often only discovered when a recipient lodges a complaint, long after delivery.

A batch is subsequently split or combined, for example because part of the consignment is reprocessed. This raises the question of whether the existing passport is amended or whether new passports are needed. In batch registration this is more prominent than in passports per item; the difference between these is described at do I register steel per batch or per piece?

A supplier delivers a corrected certificate after the passport has already been compiled and published the first time. The question then is who is responsible for implementing that change: the original data supplier, or the party hosting the passport.

An error is only discovered after the product has already been resold and processed by another party in the chain, which has meanwhile based its actions on the incorrect data — for example in a calculation of material origin or in its own product passport that builds on the passport of the semi-finished product. The latter is particularly relevant for products composed of multiple parts; how that relationship works is described at my product requires multiple product passports — how do they work together?

The delivery format of the corrected data differs from the format in which the passport was originally compiled, so that the correction cannot be loaded without further ado. What format is required for this is described at in what format must I submit the data for the product passport

What you can document

A number of matters can be arranged in advance through simple internal agreements, so that a correction later does not become a search exercise:

• A fixed point of contact within the company that receives and assesses errors in a published passport.
• An internal log in which changes to a passport are recorded: what has been amended, when, and on the basis of which document or which notification.
• A retained version of the original submission file and of each corrected file, so that an earlier version remains reconstructible.
• Agreements with suppliers on how and within what timeframe a corrected certificate or corrected composition is passed on to the party that compiles the passport.
• A fixed procedure for linking with your own ERP or inventory system, so that a correction in the source also automatically takes effect in the passport — see can I link the product passport to my ERP or inventory system?
• Clarity about which identification code belongs to which product or which batch, so that a correction always reaches the correct passport.

Once the delegated act for iron and steel has been published, it is expected to set out more specifically how a correction process should be structured. Until then, this subject is mainly something to have organised organisationally, not something for which a prescribed procedure already exists.