“Where do we start?” It’s the question we hear most often from organizations preparing for the Digital Product Passport. And the answer is more reassuring than most expect.
At the companies we assist, we always see the same pattern: after an initial inventory, 40 to 60 percent of the required DPP data is already present within the organization. That information is in technical data sheets, EPDs, CE declarations and supplier contracts. The problem is not that the data is not there, but that no one has the total overview. The information lives scattered across departments, systems and formats that were never set up with the DPP in mind.
That’s the real work: recognizing existing information, structuring it and filling in the missing pieces. Not building everything from scratch, but building on what’s already there.
Start with what you already have
Before organizations start requesting new data from vendors or engaging outside agencies, it pays to take stock of what is already available. The following documents almost always contain information that directly or indirectly maps onto the mandatory DPP fields:
| Document | Relevant DPP information |
| Technical data sheets / datasheets | Material composition, product specifications, dimensions, weight |
| Material Safety Data Sheets (MSDS). | Hazardous substances, safety information, REACH data |
| Environmental Product Declaration (EPD). | Environmental footprint, life cycle analysis, CO₂ emissions |
| CE declaration / Declaration of Conformity | Conformity, test results, standards applied |
| REACH documentation | Substances of concern, chemical composition |
| Supplier contracts and specifications. | Origin of materials, certifications |
| Quality Reports | Test results, durability data, lifetime tests |
The key is to recognize this information as DPP-relevant and structure it according to the required standards. Many organizations are surprised how much they already hold.
Where is that data internally?
DPP data is scattered across departments. That’s not a mistake; that’s just how organizations work. But for the DPP, it needs to come together into one structured whole.
- Production / Operations – material specifications, bill of materials, production locations, energy consumption, packaging composition
- Purchasing/Procurement – supplier lists, material certificates, source of raw materials, contractual sustainability requirements
- Quality / Compliance – test results, CE marking, REACH registrations, fire classification
- R&D / Product development – repairability, expected service life, disassembly instructions, availability of spare parts
- Sustainability / ESG – EPDs, LCAs, carbon footprint calculations, recycled content data
The challenge is that this information lives in different systems: ERP, PIM, PLM, Excel files, PDFs on shared disks. No single department has the big picture, which is exactly what the DPP requires. Organizations that leverage the DPP to centralize their product data find that the payoff extends beyond compliance. The same data structure proves useful for CSRD reporting, supplier reviews and product optimization.
Data to come from suppliers
Some of the DPP data cannot be generated internally. That information must come from suppliers, and it involves data points that many organizations do not yet structurally request:
- Upstream material composition – the precise composition of purchased raw materials and components
- Origin of raw materials – the origin of materials, relevant to due diligence and traceability
- Upstream carbon footprint – the CO₂ emissions in the chain before its own production step
- Certificates and statements – FSC certification, conflict minerals, due diligence, recycled content statements
- Hazardous substances – SVHCs in purchased materials, including concentrations
In our experience, this is the most time-consuming part of DPP preparation. Not because vendors don’t want to cooperate, but because they often don’t know exactly what is needed. A concrete request with specific data points and a clear format yields better and faster results than a general “we need DPP data.” How organizations can best set up that chain collaboration, we describe in the article on DPP and your supply chain.
Data to be calculated
Some DPP fields cannot be looked up in existing documents. They must be calculated, and that requires specific expertise.
Carbon footprint (Product Carbon Footprint / LCA).
The environmental footprint over the entire life cycle is the most difficult data point to complete for many products. A full life cycle analysis according to ISO 14040/14044 is considered the gold standard, but industry averages can also be used for a first estimate. For building products, an EPD according to EN 15804 offers a strong starting point.
Reparability and recyclability score.
The ESPR (EU 2024/1781) calls for an assessment of how repairable and recyclable a product is. For batteries (EU 2023/1542) and construction products (revised CPR), those requirements have already been fleshed out concretely under their own regulations. For ESPR product groups such as textiles, steel and aluminum, the methodologies will follow via delegated acts, expected in 2026, with a transition period of at least 18 months. Repairability scores are being prepared as a horizontal measure, initially focused on consumer electronics.
From documentation to DPP data: a roadmap
The path from single documents to structured DPP data need not be a monster project. The following roadmap can be started tomorrow.
- Inventory. Collect all existing product documentation in one central place: technical sheets, certificates, EPDs, supplier data. Anything that might be relevant.
- Map to DPP fields. Place the collected documentation next to the DPP fields that apply to the relevant product category . The Empact DPP Tool automates this process: upload the documents and the AI matches them to the relevant data points.
- Identify the gaps. What fields are not fillable? Categorize them: available internally but not yet structured, to be requested from suppliers, or to be calculated externally.
- Prioritize. Not all fields are equally urgent. There are always some basic mandatory ESPR fields, regardless of product category. Category-specific fields follow as soon as the delegated act for that product group appears. Start with the basics.
- Engage suppliers. Send tier 1 vendors a concrete request with specific data points and a clear format. The more specific the request, the more useful the response.
- Centralize and structure. Bring all the data together in a central system. The DPP requires machine-readable, interoperable information. A collection of individual PDFs is a starting point, not an end solution.
Starting now pays off
Organizations don’t have to have a perfect DPP to get started. It starts with taking stock of what is already there. The battery passport, mandatory from Feb. 18, 2027 under the EU Battery Regulation (EU 2023/1542), shows that the first deadlines are close. Delegated acts for textiles and steel are expected to follow shortly thereafter.
The free Empact DPP Tool performs steps 1 through 3 automatically: upload existing documents and instantly receive a gap analysis that shows which data is already available, which is missing, and from which party it can be retrieved. Organizations that want guidance in completing their dataset or setting up a data collection process towards suppliers can contact Empact. We are happy to help.