Digital Product Passport: Compliance Burden or Strategic Advantage?

Imagine buying a product and being able to instantly see where it came from, what it’s made of, how it was produced and what happens to it at the end of its life.

This level of transparency is becoming a regulatory requirement. With the Digital Product Passport (DPP), the EU is introducing new regulation that will make product information more structured and accessible across the entire value chain.

At first glance, the DPP feels like just another compliance issue. However, that perspective is too narrow. Businesses that prepare early can use the DPP to improve product data quality, strengthen supplier transparency and build a more scalable foundation for future regulatory and commercial requirements.
This doesn’t only apply to companies based in the EU. US manufacturers, global brands and other non-EU businesses that sell physical products on the European market may also be affected, depending on the product category.

This article explains what the DPP is, when it becomes relevant and why it should be treated as more than just a mandatory regulation.

What Is the EU Digital Product Passport?

The Digital Product Passport (in short: DPP) is a standard for the structured collection, processing and sharing of product-specific data. It accompanies a product throughout its lifecycle – from development and use through to recycling. Each product receives an individual digital data record that can be accessed via an identifier such as a QR code.
The DPP is a core element of the Ecodesign for Sustainable Products Regulation (ESPR). With this regulation, the EU aims to reduce resource consumption while making products more durable, repairable and easier to recycle. It’s also intended to create far greater transparency around environmental impacts across the entire value chain.
Alongside basic information such as product identification and material composition, the DPP may also include additional data, for example on repairability or guidance on proper disposal. The exact requirements will depend on the product group and the corresponding delegated acts.

Who Is Affected by the DPP?

The DPP applies to physical products. Digital products and services aren’t affected.

Although it’s an EU regulatory instrument, its relevance extends beyond EU-based manufacturers. Companies outside Europe may also need to prepare if they sell affected products into the EU, work with EU importers or distributors or supply data into regulated product categories.

In practice, this means that the DPP may become relevant for the following segments:

• Manufacturers
• Brand owners
• Importers and distributors
• Private-label retailers
• Suppliers contributing data on materials, components or product properties

When Will the DPP Become Mandatory?

The DPP will be introduced gradually, with mandatory requirements taking effect at different points in time depending on the product category. The first use case is the battery passport. From the 18th of February 2027, it will become mandatory for electric vehicle batteries, light means of transport batteries and industrial batteries.
In the following years, the concept is expected to be extended step by step to further product groups, including textiles and footwear, tyres, detergents as well as intermediate products such as iron, steel and aluminium.
A key point for companies is that, once a delegated act for a specific product group has been published, there’s generally an 18-month implementation period before the requirements become binding.
Even so, waiting for full regulatory detail is risky. Building the necessary data structures, clarifying responsibilities and setting up reliable supplier processes takes time. Companies that start only once the formal requirements are finalised may find themselves under significant pressure.

What Value Can Companies Create from DPP Readiness?

While many companies currently view the Digital Product Passport primarily as a compliance requirement, early preparation can also create tangible business benefits. Beyond meeting regulatory obligations, DPP readiness can improve transparency, efficiency and supply chain management.

More Credible Product Transparency

The DPP creates a clearer and more reliable information basis than many conventional green claims. For customers and business partners, that means greater transparency and more trust in product-related sustainability information.

More Efficient Processes

Structured product data can improve procurement, production and traceability processes. It also makes it easier to analyse usage and lifecycle information, supporting product improvements and better operational decisions.

Better Supply Chain Visibility

Since suppliers will need to provide relevant information for the DPP, companies gain much deeper insights into materials, processes and standards across the entire supply chain. This can support supplier selection and help ensure that compliance, quality and sustainability requirements are met more reliably.

Greater Regulatory Readiness

Companies that introduce the necessary structures early on can already cover parts of today’s regulatory requirements while preparing for future developments. That improves planning certainty and reduces the effort required when further rules come into force.

New Circular Business Opportunities

The DPP can also support circular business models by making product information available across the entire lifecycle. This can create better conditions for repair services, refurbishment, resale and other second-life initiatives.

DPP: What Changes on the Data Side?

The DPP changes the role of product data significantly. Product information becomes a central factor for compliant and future-oriented business operations. It’s no longer just an operational requirement, but a basis for transparency and informed decision-making across the entire product value chain.

That raises expectations around data quality and availability. DPP information is intended to rely on open, standardised data models and interoperable formats so that it can be used, exchanged and processed across systems and organisations.

A key use case is the seamless exchange of product, material and sustainability data with suppliers. In the future, this exchange will need to be more standardised, independent of systems and as automated as possible.

To make that work, companies need a consistent but flexible data foundation that can be processed by different systems and shared seamlessly across organisational boundaries. Existing IT solutions and interfaces must be able to support stronger integration and exchange.

What Data Is Typically Required for a DPP?

The exact content of a DPP depends on the product group. The specific requirements are defined by the EU in delegated acts. Even so, a clear pattern is already emerging.

Product and Identification Data

This includes the basic information required to identify a product clearly, for example serial or batch numbers, manufacturer details, production site information and relevant certifications.

Material and Substance Data

This category focuses on transparency around the materials used. It may include information on material composition, the share of recycled or bio-based raw materials and references to critical or regulated substances.

Use, Maintenance and Repair Information

The DPP is also intended to support longer product use. This includes information on operation, care and maintenance, repairability, available spare parts, guarantees and services.

End-of-Life Information

The phase after use is also part of the DPP. This may include information on disassembly, take-back options, reuse, recycling and proper disposal.

Many of these data points already exist somewhere in your business. The challenge is to structure them, make them machine-readable and link them clearly to the right product.

How to Prepare for the DPP in 5 Steps

1. Take Stock of Your Data

The first step is to gain an overview of your existing product data.

• Which information is already available?
• Which systems is it stored in?
• How up to date and how well structured is it?

For companies with broad product portfolios, it often makes sense to start with the product group that’s likely to become relevant first or where the need for action is greatest.

2. Identify the Gaps

The next step is to analyse which information is still missing for the relevant product group or isn’t yet available in the required quality.

That makes it possible to define which data needs to be added, standardised or newly created. These findings then need to be turned into separate tasks.

3. Define Ownership and Processes

Product data management isn’t a one-off exercise. To keep information consistent, complete and up to date over time, companies need clear responsibilities and well-defined internal processes.

Questions to answer include the following:

• Who’s responsible for which data sources?
• Who checks and approves the information?
• How often is the data reviewed?

Depending on the size of your organisation, it can be useful to appoint a central contact or a small team to coordinate the introduction and maintenance of DPP data. Ideally, this role works closely with development, procurement, quality assurance and management.

4. Prepare Your System Landscape

The next step is to assess whether existing systems are ready for the new requirements. Enterprise resource planning (ERP), product information management (PIM) and e-commerce systems in particular will need to work together much more closely.

A PIM system can serve as a central platform for product data. It brings together information from different source systems and suppliers, cleans it up and supports quality assurance. This allows businesses to check data completeness automatically or define required fields and validation rules.

From there, information can be distributed to different channels such as online shops, portals or marketplaces. A PIM system can also help translate data into machine-readable target formats such as JSON, XML, CSV or BMEcat.

As regulatory requirements and target systems become more complex, AI is also becoming more relevant in data processing. AI can help enrich product data automatically, manage large volumes of information more efficiently and make content available across different channels. At the same time, AI is only useful if the underlying data governance and integration are in place.

If a PIM system is expected to support these developments properly, it should be based on modern architectural principles. These include API-first structures, event-driven communication, flexible data models, multi-context capabilities and the seamless integration of external data sources.

Companies should assess early on whether their current systems can meet these technical and structural requirements or whether a future system migration may be necessary.

5. Start with a Pilot Project

Rather than trying to redesign the entire data landscape at once, it makes sense to begin with a clearly defined pilot project for one selected product group. This allows companies to run through the full DPP process once – from data collection to provision.

Typical challenges quickly become visible, for example missing supplier data or unclear responsibilities in data maintenance and approval.

On that basis, standards and structures can be developed and transferred to further product groups. A pilot project also helps create internal understanding of why technical and structural adjustments are required.

The DPP as a Foundation for Scalable Product Data Management

The DPP is one example of a broader shift. Product data is becoming a strategic capability. Companies that create scalable structures now will be better prepared – not only for DPP-related obligations, but also for future regulatory requirements, digital commerce needs and circular business models.

That’s why the DPP shouldn’t be seen as a narrow deadline-driven exercise. For companies active in the European market, it’s a signal that product transparency, supplier collaboration and interoperable data structures are becoming critical to business success. Those who act early don’t just reduce regulatory risk, but improve data quality, strengthen internal processes and build a foundation that will remain valuable well beyond the first DPP requirements.

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