How market surveillance authorities will actually check a product passport

The carrier. An inspector with a phone scans the code on the product, packaging, or documentation and sees whether it resolves — publicly, immediately, without an app, and in the language of the market. A carrier that resolves to a login wall, a dead link, or a marketing page is the fastest possible finding, and it has nothing to do with your compliance substance.

Authorities compare sources. The passport, the declaration of conformity, the technical file, the label, and the product itself must tell one story.

• Passport data that contradicts the declaration of conformity — different standards, versions, or model identifiers.
• A model or batch identifier in the passport that does not match the physical marking.
• Substance or material figures that differ from the technical file, usually because one was updated and the other was not.
• Missing responsible-economic-operator details, which is what an authority needs before it can even write to you.

A passport is a maintained record, not a launch artefact. Formulations change, suppliers change, standards are superseded, and each change should propagate. Most organisations have no trigger that connects an engineering change order to the published passport, so the data drifts quietly until somebody scans it.

The fix is procedural and cheap: add publication to the change-control checklist and give one named owner the obligation to sign off.

Take a finished unit off the line, hand it to somebody outside the compliance team with a personal phone on a mobile network, and ask them to find the recycled-content figure and the responsible operator. Time it. Whatever breaks in that ten minutes is what an inspector will find.