This article provides a framework for assessing your digital product passport readiness ahead of the finalized regulation to come in 2027. If you are ready to upgrade your data infrastructure to enable this transformation, take the next steps with our solution, TrusTrace for Digital Product Passports.
As the EU’s Ecodesign for Sustainable Products Regulation (ESPR) and related policies reshape how products are made, labeled, and reused, the Digital Product Passport (DPP) is quickly becoming a core requirement. But let’s be clear: no company today offers a complete, regulation-defined end-to-end DPP product simply because the rules do not exist in full yet.
The Delegated Acts under ESPR are still in development and expected to come in 2027, and many technical requirements—such as data models, system interoperability, and sector-specific fields—are actively being debated in EU policy forums and industry working groups. That said, you don’t need to wait. By understanding what an end-to-end DPP solution should include, you can start assessing your own readiness now and prepare your infrastructure accordingly.
This framework is our hypothesis on what we believe an end-to-end DPP system will require, based on our policy participation, pilot projects, and insights from industry working groups.
A credible DPP system must span the entire product lifecycle, from raw material extraction to end-of-life or next-life for circularity. This includes design, sourcing, production, logistics, product use, and post-consumer recovery. Lifecycle-spanning data is essential to support durability claims, recyclability insights, and circular business models.
Secondary data or outdated averages will not meet the bar for traceability and compliance. Brands will need systems that collect primary, transaction-linked data from suppliers, with verifiable documentation and real-time updates. This includes certification details, chain-of-custody evidence, and any additional proof linked to sustainability or compliance claims.
To support circular economy goals and regulatory compliance, DPPs must enable data traceability at the appropriate level of granularity. Whether model, batch, or individual item level will depend on the product group and use case. The draft DPP standards foresee item-level identification and data versioning where needed, such as repair histories, batch-specific variations, or end-of- or next-life processing.
While item-level data may not be mandatory for all products, it will be critical for certain high-impact categories (e.g., textiles, batteries, electronics) to ensure that stakeholders across the value chain – from recyclers to consumers – can reliably access and act on accurate, up-to-date information. The exact requirements for data granularity will be defined in future Delegated Acts, expected by 2027.
No two supply chains are alike. An End-to-end DPP solution must be configurable to support different sourcing strategies, materials, and regional requirements, while remaining scalable and adaptable enough to change with the dynamics of suppliers and millions of SKUs. As brands grow and regulations expand, systems that are not flexible and scalable will fail to deliver.
The DPP is not a standalone application. To support product traceability, compliance, and circular economy goals, it must seamlessly integrate with existing business systems such as PLM, ERP, POS, and regulatory compliance platforms. This is known as Interoperability. This integration is enabled by open standards including GS1 Digital Link, the European DPP (EUDPP) specifications, and W3C standards. Interoperability ensures that DPPs are portable, shareable, and actionable across the product’s entire lifecycle including resale, repair, and recycling.
Because the scope and content of delegated acts under the ESPR are still evolving, investments in DPP infrastructure should be designed for long-term adaptability. Companies are encouraged to adopt traceability systems that can accommodate future updates to delegated acts, product group requirements, and regional implementation differences. The DPP system should also support interoperability with other regulatory frameworks—both within and beyond the EU—to maximize reuse of data across compliance regimes.
To assist in this effort, we published The TrusTrace Compliance Canvas™ to help brands visualize how specific data points align with current regulations and where overlaps exist between different regulatory demands.
More than a tool for transparency, DPP is a strategic enabler of circular design. Effective solutions will be built for post-purchase activities like recyclability, repairability, disassembly instructions, and material origin that are essential for extending product life or recovering its value. This supports the stance of the DPP as infrastructure between compliance and circular business models.
Beneath the DPP surface, security and trust must be embedded by design. An end-to-end solution should include role-based access, encrypted data handling, audit trails, and GDPR-level protections. As DPP data will increasingly involve sensitive business relationships and IP, trust in the system and alignment to Standards is non-negotiable.
This framework isn’t a checklist to certify whether a provider has 'the end-to-end DPP solution.' No one does. Instead, it’s a blueprint for how to assess your own readiness:
Our current understanding of what makes an end-to-end solution is deduced from ongoing dialogue with policymakers, working groups, and brands that are already piloting DPP infrastructure. We share more of this thinking in the following resources:
While the regulatory timeline remains in a bit of flux, the direction is clear. If you act now by investing in traceability, interoperability, and data governance will be ready to comply, and ready to lead.
Let this be your internal benchmark for readiness, so you can build the infrastructure that enables your team to know, prove, and improve product impact, every step of the way.
TrusTrace helps you build a solid data foundation behind each DPP interface. Prepare for DPP compliance with confidence by leveraging our marketing leading supply chain traceability and compliance solutions. Check out TrusTrace for Digital Product Passports today.