The most common mistake when submitting data for the digital product passport is not an incorrectly filled in fibre composition or a missing certificate. It is the assumption that submitting data is a one-time action: enter it once, done. In practice, the information behind the passport must remain current as long as the product is on the market, and that can take years.
This error usually does not arise from unwillingness, but from the way companies structure the passport in their process. Data is collected at the start of a collection or import round, entered, and then considered complete. Changes that occur afterwards, such as a different supplier, an adjusted composition or a corrected test result, are no longer reported back to the passport. The result is that the QR code on the garment refers to information that no longer matches the product in the shop or webshop.
Why this so often goes wrong
In many companies, the passport is treated as part of the registration process for a new product, similar to entering an article number or barcode. Once that is done, the subject disappears from view. Whereas the regulation actually assumes a living set of data: information that belongs to the product as long as it exists, even if circumstances change at the manufacturer or importer.
A second cause is that the data often comes from multiple sources: the factory, the fabric supplier, the test lab, the company's own purchasing department. If no one within the company is designated to identify changes from these sources and pass them on, the information remains stuck at the level of the initial submission. That is not malicious negligence, it is a process that was never set up for maintenance.
What this means for ten years of storage
The regulation requires the storage and accessibility of passport data for a long period. That is precisely why this error is so persistent: with one-time submission, the problem often only becomes apparent years later, when someone scans the QR code and notices that the information no longer matches the physical product. By that time, the cause often originated long ago, somewhere in the procurement process or in a supplier change that was not communicated.
Entrepreneurs who want to prevent this would do well to determine in advance who within the company is responsible for identifying changes that affect the passport, and how often that person checks whether the recorded data still matches reality. That is not a legal exercise, it is a matter of building in a fixed moment in the existing procurement or quality process.
How to prevent this
The core of the solution is simple to formulate, even if implementation differs per company: link the maintenance of passport data to an existing recurring moment, such as an annual supplier assessment or a seasonal procurement round. This way, maintaining the passport becomes not a separate topic that can be forgotten, but a fixed part of something that is already happening.
It also helps to determine in advance which changes actually need to be reported to the party hosting the passport, and which do not. Not every internal adjustment affects the information on the passport; a change in fibre composition or production country does. If you clarify that distinction in advance, you avoid both unnecessary work and the risk that a relevant change slips through the cracks. For those who want to bring structure to this, the knowledge base with explanations per topic an overview of which data can change over time and which remain stable.
Who handles this within your organisation
At an installation company, an office organisation or a private label importer, responsibility for the digital product passport often falls implicitly to whoever already manages the procurement process. That works, as long as that person also knows which changes are relevant and who to contact if an adjustment needs to be made to the hosted digital product passport. Unclear responsibility for this is often the direct cause of the error described in this article.
The delegated act that will specify this obligation in concrete terms is expected in 2027 according to the European Commission's work plan for 2025-2030, with clothing of which eighty percent or more consists of textile fibres as the first category. Until that act is published, the exact date of entry into force remains uncertain. For your own situation, and for questions about liability for outdated data, a conversation with a lawyer or the competent supervisory authority remains the right point of contact.
Would you like to see where your company currently stands in relation to this obligation? Take the free product scan with an indication in five questions, or view the explanation of where our information comes from to see how texpas.eu arranges the submission and maintenance of digital product passport data.