We build an infrastructure where product-level material composition, production history, supply chain trail and repair information is collected, versioned and published through a data carrier. The way to be ready when the date is set is to start accumulating the data today.
The idea of a digital record travelling with the product came about when several independent demands converged at the same point. Consumers ask what the product is made of and how it can be repaired; the buying brand wants a trail of the supply chain; the recycling side wants to know the material composition; and the regulator aims to make this information accessible in a standard format. The upshot is that the product needs to carry its own record.
Although the framework of the regulation in this area has been set, the secondary legislation for individual product groups is being published in stages, and in many groups — textiles first among them — the details are not yet settled. It would therefore be wrong to give a firm date, and we recommend treating any proposal that does with caution. There is, however, an interesting aspect here: even though the detail of the requirements is uncertain, what data the infrastructure needs to collect is largely clear.
The data that needs collecting is in fact the data a factory already needs for its own operations: which raw material was used in which batch, which supplier it came from, on which line and on which date it was produced, which test and quality records exist, and which serial numbers went to which customer. Once this traceability chain is in place, it serves not only a future obligation but also today's complaint handling, recall capability and customer audits. That is why we set the work up not as a compliance project but as a traceability project.
The infrastructure we build consists of three layers. At the bottom, the bill of materials and batch traceability; in the middle, data collection from suppliers and validation; at the top, a publishing layer that presents different levels of detail to different audiences. What the consumer sees is not the same as what an auditor or a recycling facility sees; commercially sensitive data is kept separate. Once the date and format are settled, the remaining work is not collecting the data but converting ready data into the required format.
Businesses that already have to meet buying brands' traceability demands today. In this sector the demand arrives through the buyer before the regulation does, and it is becoming increasingly detailed.
Product groups where repairability, spare parts and material composition information is requested. In these groups the product information is already part of the technical file; what is missing is keeping it at product level and in an accessible form.
Sectors carrying recall risk, such as food, chemicals and packaging. Traceability is already essential in these businesses; once the infrastructure is in place, the product passport side is not an extra burden but an output of the existing structure.
Brands that outsource production. In this setup the data is created at the manufacturing site and has to reach the brand; establishing the collection process is the hardest part of the job.
Which raw material, and which lot from which supplier, was used in which batch is recorded. The chain can be queried both forwards and backwards: which products came from a raw material lot, and which lots are in a product. This is the one piece of information everyone is looking for at the moment of a recall.
The product's material composition, technical specifications, test results and documents are linked to the product record. Information is stored per product version; when the product changes, the previous version's record is preserved, because it is still valid for the older products in the field.
The collection of documents and declarations requested from suppliers is managed: what was requested from whom, when it arrived, which product and period it covers. Outstanding items remain visible. Without this flow the upper layer stays empty — and this is also the part that demands the most effort.
The QR code or similar carrier on the product points to the product's record. The published page shows different levels of detail depending on the type of viewer; information open to the consumer is separated from information disclosed to an auditor. Commercially sensitive data is never published openly.
Product information changes over time; which information is valid from which date is tracked. For a product in the field, the correct information is not today's version but the version in force when that product was made. If this distinction is not built in, the published information will be wrong.
Repair instructions, spare parts lists and end-of-life guidance are linked to the product record. Most manufacturers already have this information, but not associated with the product; it usually sits inside a manual and cannot be searched.
We decide at which level of detail the product will be traced: batch, serial number or product group. This decision directly determines the cost; tracing every unit individually is not necessary in every sector, and tracing at an unnecessary level creates an unsustainable recording burden.
We map what is recorded today and where the chain breaks. In most facilities the chain breaks at raw material intake and at subcontracted operations; these points are addressed first.
Missing recording points are set up on the shop floor; existing barcode and label infrastructure is used where available, and where it is not, the minimum required setup is discussed. Ease of shop-floor recording is essential — otherwise the chain breaks again.
The information to be requested from suppliers is defined and the collection process is launched. This step takes the longest and is run in stages; we start with the highest-volume suppliers.
The data carrier and publishing page are set up, and views are defined per viewer type. The points that will need converting once the requirements are settled are documented, so that moving to the final format becomes an adaptation task, not a rebuild.
Secondary legislation for individual product groups is being published in stages, and in many groups, textiles included, the details are not yet settled. That is why we do not give you a firm date — and we recommend treating any proposal that does with caution. The right thing to do, regardless of the date, is to start accumulating the data today, because traceability cannot be produced retrospectively.
The data the infrastructure collects is already needed for your own operations: batch traceability, supplier documents, material composition and quality records. These are also used when a complaint comes in, when a recall is needed and during a customer audit. So the investment does not go unrewarded even if the regulation is delayed. The part that is early is the format of the publishing layer — and we leave that until last.
No — the publishing layer is built to prevent exactly that. Which information is visible to whom is defined on a role basis; information opened to the consumer is separated from information opened to an auditor or a recycler. Details such as supplier names and prices are never published openly. Building this separation in from the start is far easier than adding it later.
This is the hardest part of the job and, to be honest, it cannot be solved by software alone. Which records the subcontractor must provide should be fixed in the contract, and the collection route must suit the subcontractor's capacity. A simple upload interface is enough in most cases; a complex portal usually goes unused. What matters is that it stays visible who has left what incomplete.
Then the work starts there. Without batch traceability in place, the product passport side is meaningless. It can be built as a layer running alongside your ERP; there is no need to replace the ERP. Once it is in place, its first benefit is not the passport but being able to see what goes where in your production.
A traceability chain working at batch and lot level; a versioned product data model; a supplier data collection flow with gap tracking; a publishing layer accessed via QR code and differentiated by viewer type; and documentation describing how to adapt it once the requirements are settled. The source code and the collected traceability data are one hundred per cent yours.
In a 30-minute discovery call we listen to what you need and tell you honestly whether custom development or an off-the-shelf product is the better answer.
If your business depends on a program whose developer can no longer be reached, whose source code is incomplete or which has no documentation at all, we take that system over, establish how it works on the basis of evidence, and bring it back to a state where it can live on.
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Details →We turn a working piece of software written for a single client into a sellable product: separating the core from the client-specific layer, a configuration engine, multi-tenant data isolation, installation and release management, and subscription infrastructure.
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