Document after-sales.

Products do not stop existing after they are sold

The ESPR does not make the product passport a one-time file. Product-group delegated acts define which data must be kept up to date, who updates it and how long it remains available. For the Battery Passport, the Battery Regulation requires long-term availability of affected battery-passport data.

EU Right to Repair Directive 2024/1799 adds to this frame for goods in scope: consumers should receive easier access to repair services, and manufacturers must offer repair for certain goods where repair is possible. Nulara lets manufacturers document after-sales events in a structured way on the product without overwriting the original signed credential.

What manufacturers document in after-sales

After delivery, product data continues to accumulate. Capturing it in line with regulatory obligations and internal quality requirements keeps the passport current and defensible.

• Repair & service: Service events, replaced components and workshop reports on individual items — as evidence for repair processes and product-related service history.
• Recalls & credential status: Set product status to recalled, suspended or replaced — machine-readable as a status or event record without rewriting the original credential content.
• Warranty-relevant evidence: Repair certificates, inspection reports and manufacturer warranties versioned directly on the product.
• End of life & second life: State-of-health data, recycling events and material-recovery documents — especially for affected batteries and authorized roles under Annex XIII.

The product passport as a living record

A product passport is not a one-time requirement that ends at delivery. Nulara treats it as a living record: status changes and new service documents are linked to the existing product record as versioned entries while the original credential remains verifiable.

For recyclers, repair operators and market-surveillance authorities, this is decisive: they see the same verifiable passport the manufacturer issued — plus all documented events since.

Sources and next steps

ESPR, the Right to Repair Directive, the Battery Regulation and W3C status lists define the frame for updates, repair, access and status communication after placing on the market.

Frequently asked questions

Can I add after-sales events to an already-issued passport?

Yes. Nulara allows adding new records and documents to a product without overwriting the original signed credential. Status changes such as recalls can be represented as versioned events or credential-status information.

What does EU Right to Repair Directive 2024/1799 require from manufacturers?

Directive 2024/1799 creates consumer rights and manufacturer repair obligations for goods in scope where repair is possible. In a DPP context, repair information, service documents and component data should stay versioned and access-controlled where they are relevant for the product type.

Which roles can see after-sales data?

That depends on the product type, access right and delegated act. For affected batteries, Annex XIII distinguishes public, restricted, authority/notified-body and individual-battery data. Nulara supports differentiated access rights at record level.