Global manufacturing is entering a new era of product transparency, where Digital Product Passports (DPPs), including Digital Battery Passports, are set to become the standard way manufacturers and distributors provide verified product sustainability data to their customers and regulators.
While requirements begin with specific high-impact categories in 2027 under the Ecodesign for Sustainable Products Regulation (ESPR), the scope will progressively widen until almost every product group is covered. But beyond deadlines, there is an even more pressing need for accurate, verified supply chain data from your organization. Your customer’s expectations are accelerating ahead of enforcement dates so they can prepare for their own product passports, and supply chain transparency is becoming embedded in procurement decisions earlier in the process than ever before. If your organization cannot quickly respond to customer data requests with accurate, verified data, your revenue will be at risk before regulatory deadlines even hit your calendar.
For manufacturers preparing to meet DPP requirements, it’s critical to ready your sustainability programs and product strategy for a permanent change in how products are evaluated and placed on the market. Product passports will be crucial for making verifiable product claims, preserving customer relationships, and unlocking continued market access.
Delegated Act Deadlines
Delegated acts for the Ecodesign for Sustainable Products Regulation (ESPR) will specify DPP content based on product groups. Here are some upcoming dates to keep in mind:
- 2026: Delegated acts for iron and steel
- 2027: Delegated acts for aluminum, textiles, tires, and horizontal measures for information and communications technology (ICT)
- February 2027: Digital Battery Passport requirements expected to take effect
- 2027+: Incremental rollout for additional product groups
Steps to DPP Readiness
Manufacturers who are proactive about DPP readiness are building a strong, scalable data foundation that will support their requirements today and in the future. It can be approached in two distinct phases:
Phase 1: Build the Strategic Foundation
This phase should begin before delegated acts apply to your product category.
1. Secure Executive Sponsorship & Educate the Organization
Start with internal workshops that clarify regulatory direction, customer expectations, and non-compliance risk. Formalize executive sponsorship and establish a cross-functional working group that includes R&D, IT, legal, procurement, and compliance.
2. Centralize & Structure Your Data
Consolidate existing material and product data into a centralized system. Extract relevant information from technical files, material specifications, and supplier documentation. Identify what supply chain information you already track, and what location(s) or system(s) it resides in. Then shift your focus to data centralization, a critical component of an audit-ready data foundation.
3. Conduct a Comprehensive Gap Analysis
Audit your technical documentation against ESPR-aligned expectations to reveal data gaps and outdated information. Review recycled content metrics, carbon footprint data, hazardous substance declarations, and other relevant attributes. To predict requirements while definitive acts are pending, monitor updated methodology reports and product-specific preparatory studies that now prioritize circularity and market resilience alongside energy efficiency. Assign internal data stewards responsible for closing gaps to help maintain accountability.
4. Embed Compliance & Circularity Into Design
Integrate ecodesign principles and material substitution strategies into product roadmaps. Evaluate product longevity, repairability, re-manufacturing potential, and innovation cycles. Align your product life cycle planning with regulatory timelines to avoid late-stage redesigns. Establish a process to map the EU’s Unique Product Identifier (UID) to your internal serial numbers now to ensure every individual unit, not just the product model, is ready for life cycle tracking and compliance.
Phase 2: Implementation
Once delegated acts apply to your category, the focus moves from preparation to implementation.
5. Conduct Conformity Assessments
Perform formal conformity assessments aligned to your product group’s delegated act. Update technical documentation and draft the EU Declaration of Conformity. Drafting the declaration often identifies residual data gaps to be addressed.
6. Orchestrate & Host the Passport
Create your Digital Product Passport using verifiable supply chain data. Define access levels for consumers, recyclers, and regulators. Finalize hosting arrangements, designate a backup provider, establish UID mapping protocols, and implement backup and recovery procedures.
7. Label & Launch
Affix the appropriate data carrier (QR code, NFC, or RFID) alongside the CE marking. Ensure your DPP is live in the EU Registry before placing the product on the market. At this point, passport readiness becomes a condition of market entry.
Early Readiness Creates a Strategic Advantage
Preparing your organization for upcoming DPP delegated act requirements and proactively addressing customer inquiries for data have several strategic advantages for your business. You’ll benefit from:
- Faster responses to customer data requests
- Better supplier engagement
- More resilient product development processes, and less risk of redesign
- Clearer product claims
- Scalable compliance data infrastructure
Waiting for looming DPP deadlines and an onslaught of customer requests to arrive before you take action will only compress your compliance timelines and create operational strain. The smart move for manufacturers in the midst of growing DPP requirements is to protect their customer relationships, brand reputation, and market access with early, proactive work on their data foundation. Those who partner with a solution provider like Assent for centralized, accurate supply chain data, better supplier engagement, and expert regulatory guidance will reduce their uncertainty and ensure their programs are ready to scale.
Learn more about Assent at www.assent.com
Author: Dr. Roxy Swails
Manager, Regulatory & Sustainability, Assent
