A digital product passport is not a sticker you apply once and then forget about. If the composition of a clothing item changes, you switch suppliers, or the manufacturer adjusts something in the production process, the information in the passport should reflect that change. If the passport remains unchanged while the product does change, a discrepancy arises between what the QR code shows and what actually sits on the shelf or in the webshop.
What happens then in concrete terms depends on who notices the discrepancy and how significant it is: a supervisory authority conducting spot checks, a trading partner asking questions, or a customer who scans the QR code and reads something different than expected. The regulation itself describes the obligation to keep information correct and up to date, but does not specify what happens in every conceivable case if that fails. This makes the subject difficult to capture in a single sentence, and precisely for that reason it is good to know where the key points of attention lie.
What 'keeping up to date' means in practice
The passport contains data that is linked to a specific product or specific product line: fibre composition, origin, care instructions, and other information prescribed by the regulation. As soon as any of that data changes—for example because a supplier uses different yarn or because part of the production shifts to another country—the underlying reality changes. The passport attached to that product line must reflect that change. If it doesn't, the QR code continues to point to data that no longer match. In the knowledge base in the section on the passport in practice it is explained which changes typically require an update and which do not.
Who can notice the discrepancy
An outdated passport rarely becomes visible by itself. It comes to light in a few ways: a supervisory authority conducting market surveillance and comparing data with the physical product, a buyer at a trading partner who checks the passport before placing an order, or a consumer who scans the QR code and reports a discrepancy. None of these situations is inherently dramatic, but they do show that a passport that has not been updated is not just an internal administrative matter. It is something that becomes visible to the outside world as soon as someone looks at it.
What is at stake
The regulation leaves the precise sanctions to the competent supervisory authorities in the Member States, and which measures they take depends on the nature and severity of the discrepancy. What can be described is this: supervisory authorities look at market surveillance to see whether the information in the passport matches the product, and a structurally outdated passport stands out more readily than a one-off, minor discrepancy. In addition, there is a practical aspect: a passport that does not match undermines the purpose for which it is intended, namely that everyone in the chain—from supervisory authority to consumer—can rely on the information. That trust is also a commercial concern, separate from what a supervisory authority formally thinks of it.
The role of your contracts and suppliers
In practice, an outdated passport usually does not arise from unwillingness, but because no one in the chain has explicitly agreed on who should report a change. A supplier that adapts a material does not automatically think of the passport you hold. For this reason, it is useful to set out in agreements with suppliers when and how changes will be reported, so that the passport can be updated before the problem arises. In the frequently asked questions it is explained which situations in practice most often lead to an update.
What you can do about it now
It starts with having visibility into where your data comes from and how quickly a change reaches you. If you have product information spread across multiple suppliers and internal systems, you will need more time to implement a change than if you have one central overview. On the page about how the process works you can read how we compile the digital product passport from the data you and your suppliers provide, and how a change is processed as soon as it occurs.
Whether keeping your records up to date is a matter of a few fields or a larger operation depends on how your supply chain is organized. With the free product scan you can see in a few questions where your situation roughly stands. For precise guidance on your own situation, we refer you to a lawyer or to the competent supervisory authority; this article describes the main points, not your specific case.