Digital Product Passports are coming - what do we know so far?

In March, the EU published a methodology for defining data requirements for Digital Product Passports (DPP).

It is a 120-page document and, while not an easy read, it provides a very important signal for companies operating in the EU. Digital Product Passports are not just another compliance topic - they will fundamentally change how product data is structured, managed, and shared.

What is important to understand is that this document is not a technical specification. It does not define APIs, system architecture, or a ready-to-use data model. Instead, it outlines a methodology for determining what data should be included in a DPP. In other words, it is a blueprint for how future regulatory requirements will be defined through delegated acts.

At its core, DPP is not a system. It is a structured, interoperable dataset that follows a product across its lifecycle. The EU defines what data must exist and how it should be accessible, but companies are responsible for how this is implemented within their own systems and processes.

One of the most important aspects of the methodology is its pragmatic approach. The EU explicitly acknowledges that not all data should be collected at any cost. Decisions such as whether to track products at item, batch, or model level will depend on feasibility and business value. The same applies to supplier transparency and data granularity. The guiding principle is clear: data should only be included if it creates meaningful value relative to the effort required to collect and maintain it.

Another key concept is the absence of a single universal data model. Instead, the EU is pushing for a common vocabulary combined with industry-specific extensions. This means each sector will define its own structure based on shared definitions. As a result, there will be no “one-size-fits-all” implementation of DPP.

It is also worth noting that DPP is not limited to structured data. It may include documentation such as user manuals, installation instructions, and safety information - anything that helps extend the product’s lifecycle. This introduces additional requirements around document management, versioning, and accessibility.

From a responsibility perspective, the burden lies primarily with manufacturers and, in the case of imports, with importers. They are responsible for creating and maintaining the Digital Product Passport. Distributors and retailers, on the other hand, are not required to generate DPP data but must ensure that the products they sell are compliant. This effectively turns them into enforcement points within the value chain.

Looking at how similar regulatory changes have played out historically, it is very likely that large software vendors such as SAP will embed DPP capabilities into their existing systems. ERP and PLM platforms already act as the primary source of product and supply chain data, and vendors have a long track record of integrating regulatory requirements directly into their offerings. However, these platforms typically do not address cross-system integration, data orchestration, or custom data mappings, which remain significant challenges for most organizations.

This leads to the real complexity behind DPP. The challenge is not creating a new system, but integrating existing ones. Companies will need to consolidate data from multiple sources, align it with evolving standards, maintain it over time, and expose it to different stakeholders in a controlled way. This is fundamentally a data integration and governance problem.

There is also an interesting discussion around SMEs. While DPP obligations mainly apply to manufacturers and importers - and many of them are not small companies - there is still a segment of smaller players that will struggle with compliance due to lack of systems and structured data. The opportunity here is not in building generic tools, but in simplifying compliance and helping these companies generate and manage the required data.

Finally, it is important to recognize that DPP will not be static. The EU clearly positions this as an evolving framework, where requirements will be refined over time based on real-world feedback. This means companies should not aim for a “final solution,” but rather for flexible and adaptable architectures.

Digital Product Passports represent a shift towards structured, transparent, and lifecycle-driven product data. Organizations that approach this purely as a compliance exercise will likely face ongoing challenges. Those that treat it as a broader data transformation initiative will be better positioned in the long term.

From our perspective at EADX, this is not about building a single product, but about enabling companies to become DPP-ready through integration, data modeling, and governance. That is where the real work - and the real value - will be.