The data: where it lives today

I'm Daniel Carlman, and this is DPP Academy. Today: the data a passport draws on, and where it tends to live already.

What goes into a passport is chosen, product group by product group, from a list in Annex III of ESPR. The delegated act for each group says what must, or can, be included.

The list covers product information, such as performance, repair and end of life. Substances of concern. Compliance documents and manuals. And identifiers for the product, the companies and the facilities.

For substances of concern, the information must include at least: the name of the substance, where it sits in the product, its concentration, and how to use the product safely and handle it at end of life.

In practice, much of this exists already, but spread out. Product data often sits in a PIM or an ERP. Material and substance data often comes from suppliers. Certificates, declarations and test reports usually live as documents.

Wherever it lives, the law is clear: the data in the passport must be accurate, complete and up to date. So the passport has to follow the systems it draws from.

Who is responsible? The manufacturer must make sure a passport is available. So must the importer. And each delegated act says who may create or update which data.

A practical start: list the data your product group will need. Find the system that owns each field. And mark the gaps.

I'm Daniel. See you in episode ten.

Next time: why a passport must outlive its vendor. This is not legal advice.