I have discovered an error in a published product passport, can I still adjust that

What you must do concretely

What is expected of you

The data must be current and correct as long as the passport exists

Article 10 of the ESPR (Regulation (EU) 2024/1781) sets requirements for how the digital product passport works: the data must remain accessible, reliable and current as long as the passport must be made available by law. This is not a snapshot at publication, but an ongoing expectation. For a company with 10 to 100 employees, this means in practice that someone must be responsible for the passport after it goes live — not only for creating it. At many companies, that responsibility lies with whoever had the passport compiled, but without a documented process, correction after publication easily falls through the cracks.

The passport remains linked to one unique product

Article 9 of the ESPR describes the digital product passport as something that is linked to a product via a unique identification. That link does not break if there is an error in the content — the identification remains in place, only the data behind it can change. That distinction is important: correcting an error is in most cases a matter of adjusting the underlying data, not of creating a new identification code. How that identification code works exactly and why it must be unique per product is described in how do I give each product a unique identification code?

The QR code and the link to the passport remain the same

Because the QR code on the garment or label refers to a fixed location where the passport can be consulted, a correction in the content of the passport does not need to change that code itself. That is also why an error is often easy to correct in practice: the carrier on the product remains unchanged, only what lies behind it is adjusted. More on how that link works technically can be found at how does the QR code for the product passport end up on my clothing and textiles?

Where things go wrong in practice

A common situation is that an error is discovered in the fibre composition after a collection is already in the store. The label with the QR code is already sewn onto thousands of pieces, and the question arises whether it still makes sense to correct the passport. Because the passport is a separate layer apart from the physical label, that is usually the case: the data behind the QR code can be adjusted, even if the label itself can no longer be changed.

Another situation arises when an importer has supplied the data, but the platform or the party hosting the passport no longer knows who within their own company is authorized to request a correction. At companies where product information flows through multiple departments — purchasing, quality, marketing — there is often no designated point of contact for changes after publication.

A third situation: an error is only noticed after the product is no longer available for purchase. This raises the question of whether correction is still necessary, since no one is buying the product anymore. But because the product passport must remain available for as long as specified — see how long must a product passport remain available? — the content remains relevant for anyone who already owns the product, even after the collection has sold out.

A fourth situation arises with private label: the brand on the label belongs to the retailer, but the underlying production data comes from the manufacturer or importer. If an error is discovered, it is not always immediately clear who may or must carry out the correction — the party that had the passport compiled, or the party that provided the original data.

A fifth, technical situation: a company has linked the product passport to its own ERP system and expects that a correction in the ERP will automatically take effect in the passport. If that link is not properly set up, the error remains visible in the passport while the source has already been corrected. How such a link works and where the pitfalls lie is described in can I link the product passport to my ERP or inventory system?

What you can record

• An internal responsible party per product line for the accuracy of passport data, including after publication — not just for providing the initial version.
• A fixed process for correction requests: who reports the error, where it is reported, and within which steps it is processed. This does not need to be a heavy document, but it should be a documented agreement between the company and the party hosting the passport.
• An overview of who supplies the source data in the case of private label or collaboration with a manufacturer or importer, so that when an error occurs, it is immediately clear where the correction begins.
• A log of changes after publication: what was adjusted, when, and who requested it. This is useful for inquiries from customers or supervisors, and aligns with the expectation from Article 10 that data remains current.
• Agreements on the link with your own system, if the passport is connected to an ERP or inventory system, so that an adjustment in the source actually makes it into the published passport.
• A check for assembled products or whether a correction to one component has consequences for a linked passport, as described in my product requires multiple product passports — how do they work together?

A published passport is therefore not a closed document. The regulation is based on a living dataset that is accurate throughout the entire availability period, and correction after discovering an error fits within that approach — as long as the company knows who is responsible for what and via which route an adjustment is made.