If you don't prepare your staff for the digital product passport, the risk does not lie in a fine from a supervisory authority — the regulation itself sets no requirements for informing employees. The risk lies in execution: data that does not arrive on time, errors in the passport that must be corrected later, and a small number of people who take on the work without anything in return.
Additionally, unprepared implementation of new work processes or software may touch on obligations that already existed, separate from the product passport: the way you inform employees about changes in their work, and the role of the works council if those changes are far-reaching enough. These are not new rules, but existing rules that become relevant again through the passport.
What goes wrong in practice without preparation
Compiling a product passport requires data that is often scattered across purchasing, quality control and administration: certificates, origin, composition, sometimes a CO2 indication. If no one knows in advance who will provide which piece, that work falls to the person who happens to receive the request — usually the quality manager or the administration. This accumulation does not result in a fine, but it does cause delays, frustration and a greater chance of errors in the final data.
A second consequence is less visible: if employees do not know why certain data is now being recorded more strictly, resistance or carelessness arises in filling it in. A passport compiled from incomplete or outdated information is harder to correct than one built correctly the first time. If you think this through in advance, you can look up in the knowledge bank by subject which data are relevant for your situation, before the work is distributed.
Who this affects in your company
In most SMEs, it is the same people who are already responsible for product documentation: someone in purchasing, someone in quality, and often the director themselves for final review. Without preparation, there is no discussion about who takes on which part, who is the contact person towards a software supplier, and who verifies whether a passport is complete before it goes out the door. This is not a legal risk, but it is a practical risk for process continuity.
When the works council comes into play
If the implementation of the passport is accompanied by new software, new working methods or a different distribution of tasks, this may fall under existing employee participation rules. Whether and when approval of the works council is needed depends on the specific situation in your company and is something the Works Councils Act provides clarification on — not the product passport itself. Companies that are uncertain about this would do well to discuss it early with their works council or with a lawyer, rather than only reaching out once the software has been purchased.
What does not change automatically
The product passport adds a new obligation, but does not replace any existing rules. Agreements on working hours, instruction and safety in the workplace remain unchanged, even if the work itself changes due to new software or new reporting requirements. If you lose sight of this, you run not the risk that the passport is incorrect, but rather that an existing obligation elsewhere is forgotten while attention is directed to the passport.
How to tackle this practically
The most common approach among companies that manage this well is straightforward: identify early on who will provide which data, explain this briefly to the employees involved, and only then select a software supplier or hosting party. This way you avoid the product passport becoming a project that lands on one person's desk. A good starting point is to review how the data for a product passport is created, so that you know in advance which roles within your organisation are needed.
Here too, the following applies: this article describes the practical implications in general terms, not your specific situation. For questions about employee representation, employment conditions or the concrete division of tasks in your company, a legal professional or the competent authority is the right point of contact.
Do you want to find out first where your company stands exactly before discussing this within your team? Take the free quick scan in a few questions, or read the other topics in the frequently asked questions about the digital product passport.