The most common mistake when choosing a software supplier for the digital product passport is assuming that the supplier thereby also takes on the responsibility. A software company can supply technology: a system to enter data, generate a QR code and host files. However, the regulation places the obligations with the manufacturer, importer or other party acting as a supplier — not with the party that builds or hosts the software.
You usually only notice the consequences of this mistake when it is too late: data that turns out to be out of date, a system that does not meet what supervisors expect, or unclear who is allowed to change which information. This can be solved, but then costs extra time and money that could have been avoided with a few questions asked beforehand.
Why this mistake happens so often
The confusion is understandable. A digital product passport is new territory for most companies in steel trading and metal processing, while software choices are often made in the same way for years: based on price, ease of use and what the IT department is used to. However, with a product passport, questions also come into play that have nothing to do with technology, such as who checks the data, how long it must be kept and who is liable if a piece of data is incorrect. These questions easily fade into the background in a conversation that is about screens and functionalities.
Moreover, suppliers understandably present their product in a positive light. Terms such as "fully compliant" or "complies with the regulation" sound reassuring, but say little about the question of who remains responsible for the content of the passport. Software can store and display a passport technically correctly; whether the data in it is correct and up to date remains a matter for the person who supplies it.
What goes wrong in practice
A few situations come up regularly. A company concludes a software contract without establishing who updates the data after delivery, and realizes after a year that no one does this structurally. Or a supplier stops the service and the data turns out not to be transferable to another system without extra costs. It also happens that a company assumes that the ten-year hosting period is automatically arranged, when in practice it requires a separate agreement.
None of these situations is dramatic if you see them coming in time. It only becomes annoying when a supervisor, customer or trading partner asks for access and it turns out that no one is quite sure where the current data is or who supplied it.
How to prevent this
The essence is simple: when choosing a software supplier, ask not only technical questions, but also questions about roles and responsibilities. Who remains the owner of the data? Who is the point of contact if a piece of data turns out to be incorrect? How is the ten-year hosting period arranged, even if you ever switch suppliers? And how is it made traceable where a piece of data comes from, so that you can show that if asked?
These questions belong in the contract, not just in a sales conversation. A supplier who can answer them clearly gives you more certainty than a supplier who speaks mainly in functionalities. In how we organize data traceability you will find an example of what such an answer can look like substantively.
What is and is not part of the software
A software supplier can help you with recording, displaying and securing data. That is valuable work, and a well-organized environment saves you a lot of manual labor. But the substantive choices — which data are mandatory, who qualifies as a provider, and when data must be updated — remain a matter for your own business. If you mix these two things up, you risk that nobody in the organization feels truly responsible for the content.
To get that distinction clear, it is useful first to have a clear picture of what role your business itself plays in the chain. That also determines which questions you should ask a supplier. In the knowledge base, selected per situation this is worked out per topic, with reference to the official text.
For your own situation, and for the precise explanation of roles and liability, it is advisable to consult a lawyer or contact the competent supervisory authority. This article describes a common pattern, not advice for one specific business.
Would you first like to map out your position before talking to a supplier? With the free quick-scan in five questions you get a first indication, and in the answers to frequently asked questions you will find more of this kind of practical situations.