Digital Product Passport: Data Management Challenges

Understanding the DPP

The Digital Product Passport (DPP) is a groundbreaking initiative by the European Union designed to enhance transparency, sustainability, and accountability across product lifecycles.

At its core, the DPP will be a digital record that provides detailed information about a product’s environmental impact, materials, and recyclability. Accessible via QR codes, RFID tags, or web-based platforms, it will empower consumers, businesses, and regulators to make informed decisions that support the transition to a circular economy.

The primary goal of the DPP is to promote sustainable consumption and production. By offering clear and reliable data, it enables consumers to choose products with lower environmental footprints, while encouraging manufacturers to design for durability, repairability, and recyclability. This aligns with the EU’s Circular Economy Action Plan and European Green Deal, which aim to reduce waste, cut carbon emissions, and foster resource efficiency.

The DPP will include a wide range of information, such as the product’s material composition, carbon footprint, supply chain details, and end-of-life recycling instructions.

Initially targeting high-impact sectors like electronics, textiles, and batteries, the DPP is expected to expand to other industries over time, becoming a universal standard for product transparency.

For businesses, the DPP represents both a challenge and an opportunity. While it requires significant adjustments to data collection and management processes, it also offers a chance to build trust with consumers, differentiate from competitors, and drive innovation in sustainable practices.

As the DPP rolls out, it will play a pivotal role in reshaping how products are designed, manufactured, and consumed in the EU and beyond.

Data Challenges

At its core, the Digital Product Passport is a data-driven initiative, making its successful implementation dependent on a company’s ability to manage, integrate, and govern vast amounts of product information. This shift will have far-reaching implications for data strategy, IT infrastructure, and regulatory compliance, requiring businesses to rethink how they collect, store, and share information both internally and across supply chains.

In the following sections, we will explore the key data challenges, from standardization and interoperability to security and real-time updates.

Data Collection and Integration

Data for the DPP can come from multiple sources, including internal systems (e.g., ERP, PIM, PLM), supplier inputs, or third-party certifications. For example, a textile manufacturer might collect data on fabric composition from suppliers, energy usage from production facilities, and certifications from third-party auditors. Companies must establish robust processes and infrastructure to collect and integrate this information seamlessly.

Data Standardization

Implementing the Digital Product Passport (DPP) requires standardized data formats to ensure consistency and interoperability across industries and supply chains. However, the European Union has yet to finalize these specific technical standards, creating uncertainty for businesses preparing to comply with future requirements.

In the absence of official guidelines, companies must navigate fragmented industry practices and varying reporting frameworks. Existing standards like ISO 14040 (Life Cycle Assessment) and ISO 14067 (Carbon Footprint of Products) offer temporary reference points, but they may not fully address the broader scope of future DPP requirements.

Another challenge lies in ensuring data consistency across complex supply chains, where multiple stakeholders operate with different levels of technological readiness. Without clear protocols, discrepancies in data collection, formatting, and sharing can lead to inefficiencies and compliance risks.

To mitigate these challenges, businesses should prioritize flexible data management strategies that can adapt to evolving standards. Engaging in industry initiatives and fostering collaboration with supply chain partners will also be critical in aligning data practices ahead of formal regulatory mandates.

Data Verification

Ensuring the accuracy, reliability, and timeliness of data collected for the DPP is one of the most critical challenges for businesses. With multiple stakeholders contributing data across complex supply chains, inconsistencies and errors can easily arise.

Companies must establish robust internal data governance frameworks, including regular audits and cross-departmental collaboration, to validate information at every stage. This ensures that data reflects the true environmental impact, material composition, and recyclability of products.

To further enhance data credibility, businesses may need to engage third-party auditors to verify key aspects of the DPP, such as the origin of materials, production processes, and end-of-life recyclability.

Additionally, adopting standardized data formats and integrating advanced data management systems can streamline the collection and validation process, reducing the risk of errors.

Data Interoperability

Businesses must ensure that their data management systems can communicate seamlessly with relevant systems across the supply chain, as well as with EU-managed platforms (such as the central DPP registry) and third-party DPP service providers.

To enable seamless communication between systems, businesses will need to adopt standardized protocols for data exchange. These protocols will likely be defined by the EU as part of the DPP framework and may include specific data formats, APIs, or communication standards.

Real-Time Updates

For certain product categories, such as batteries for electric vehicles, each individual unit will have its own unique digital passport. In addition to static data — such as specifications, manufacturer details, and material composition — the passport will also include dynamic data, which evolves throughout the product’s lifecycle and must be updated in real-time. These data points may include usage history, performance metrics, carbon footprint tracking, and repair and maintenance records.

Managing and integrating real-time data into DPPs presents a significant challenge. Ensuring data accuracy, consistency, and security requires robust digital infrastructure capable of continuously collecting, processing, and updating records.

Data Security and Privacy

With multiple stakeholders granted access to DPP data under the Ecodesign for Sustainable Products Regulation (ESPR), ensuring security and controlled access is essential. While some DPP information will be publicly available, other data will be restricted based on user roles, requiring robust access management protocols to prevent unauthorized disclosure or misuse.

Balancing transparency with data protection is a key challenge. Sensitive information — such as supplier networks, production methods, and material compositions — must be shielded from competitors while remaining accessible to authorized entities, including market regulators, repairers, and recyclers. Implementing granular permission controls will be crucial to safeguard proprietary data without compromising the DPP’s intended benefits.

Compliance with GDPR and other data protection regulations further adds complexity. While most DPP data pertains to products, occasional inclusion of personal details (e.g., supplier contacts) necessitates strict security measures, encryption, and clear data governance policies. Businesses must ensure that only the right stakeholders can access specific datasets while maintaining full regulatory compliance.

Conclusion

The Digital Product Passport marks a major shift in how product information is collected, shared, and utilized. While it presents numerous data management challenges, it also unlocks opportunities for businesses to enhance transparency, build trust, and drive sustainability. For companies, success will depend on proactive data strategies, flexible digital infrastructure, and collaboration across supply chains.

You may also like:

• Blog article: “Digital Product Passport: Tips to Unlock New Opportunities in E-Commerce”
• E-book: “ESG – It is our responsibility”
• Booklet (PDF): “Digital Product Passport: All you need to know”