Yes, you can compile part of the digital product passport yourself: the data you as a manufacturer, importer or distributor already have in-house, such as certificates, test results and origin information, you can supply and organize yourself. Where it becomes more difficult is converting that data into the fixed technical format that the regulation will prescribe, generating the unique identification code and keeping the passport accessible for ten years via a QR code. That is the part for which most companies engage a specialized party.
The boundary between doing it yourself and outsourcing therefore does not lie in the content of your data, but in the technology around it. You are and remain responsible for the accuracy of what appears in the passport; a software supplier or platform takes care of the form in which this happens and for availability in the long term.
What you can prepare yourself
The data that ends up in a product passport for iron and steel, you in many cases already have somewhere: chemical composition, mechanical properties, origin of the raw material, any recycling percentages and existing certificates according to standards you already use. Collecting and organizing that documentation is work you can perfectly do yourself, and where you also have the most insight. Whoever gets this in order beforehand, does not have to search for documents in a panic once an obligation becomes concrete.
What usually does not happen internally
The more difficult part lies in three points. First the technical format: the regulation uses delegated acts that establish for each product group which data is mandatory and in what form it must be submitted. Building a system yourself that continues to meet these requirements requires ongoing maintenance, even if the rules are supplemented over time. Second the unique identification code and its linking to a QR code that works for ten years, even if your company switches systems or a product changes ownership. Third the hosting itself: the passport must remain accessible throughout the entire retention period, even when a supplier ceases operations or a server is replaced. That requires a different setup than a regular company website.
Building yourself: what to bear in mind
Companies considering building this internally mainly run up against the cost of maintenance. Once the first delegated act is published, the technical implementation may change, and that change must then be implemented in your own system. That is not a one-time project but a recurring obligation. For companies for which the product passport is a small part of operations, that maintenance often does not outweigh outsourcing that specific technical part.
What a platform like ferropas.eu does in this
Ferropas.eu compiles the passport from the data you as a manufacturer or importer supply, hosts it for the statutory period of ten years and provides the QR data carrier that refers to that passport. Your own role remains supplying and keeping the correct data up to date; the platform takes care of the technical processing and long-term availability. On how we process the data into a passport you can see exactly where the information in the passport comes from and who remains responsible for what.
Whether building it yourself is feasible for your situation depends on how many product groups you carry, how often your assortment changes, and how much capacity you want to structurally free up for maintenance of a technical system. This is an assessment that differs per company, and the regulation itself makes no statement about it: it sets requirements for the result, not for the way you organize it.
First an indication, then a choice
Before you choose between building it yourself and outsourcing, it is useful to first clarify which data you already have and which are still missing. In the knowledge base with elaborated topics per situation you will find an overview per role in the chain, from manufacturer to distributor. If you want to know sooner where your company approximately stands, then the quick-scan with a few short questions provides a first indication, completely free and without needing an account.
If you have a concrete question about your own situation after reading this, then a lawyer or the competent supervisory authority is the right party to assess that; this article describes the regulation in general terms and makes no statement about individual cases. For the most frequently asked questions about costs, deadlines and what is and is not covered by the passport, you can also go to the page with answers to frequently asked questions.