Creating a Digital Product Passport based only on your own data is not feasible. The DPP requires information from the entire chain, from raw material extraction to end user, and that data comes from parties you don’t always have direct control over. In this article: who is responsible for what, how does data exchange work in the chain, and how do you organize cooperation?
Why the DPP is a chain project
The ESPR (EU 2024/1781) is clear on the usefulness and necessity of the DPP, it contains information on the entire product life cycle. A simple example makes this concrete. Take a cotton T-shirt. The origin of the cotton at the farm, the spinning mill that turns it into yarn, the weaving mill that turns it into fabric, the garment maker that turns it into a shirt, the dyer that dyes it and the chemicals used in the process, and the carbon footprint of each of these steps. No single party in this chain has all the information. The DPP requires cooperation, regardless of whether that cooperation is easy to organize.
At the companies we assist, we always see the same pattern: the internal data is often already reasonably in order, but as soon as upstream information is needed, the time-consuming work begins. Not because suppliers are unwilling, but because the information demand is new and the structure to share data in a standardized way is often still lacking.
Responsibility by chain role
The ESPR imposes clear obligations by type of economic operator. That division of roles determines not only who must do what, but also where legal liability lies when the DPP is not in order.
Manufacturer
The manufacturer bears primary responsibility for creating and maintaining the DPP. In concrete terms this means: compiling the DPP on the basis of its own data as well as supplier data, ensuring that the product meets all ecodesign requirements, affixing the data carrier to the product (QR code, NFC tag or RFID), registering the DPP in the EU DPP Registry (which must be operational by July 19, 2026 at the latest) and keeping the technical documentation for at least ten years.
Thus, the manufacturer is formally responsible, but at the same time dependent on upstream data. Without cooperation from suppliers, a complete DPP cannot be put together. That makes collecting supplier data not an optional step, but a core part of the DPP process.
Importer
When the manufacturer is located outside the EU, significantly more responsibility shifts to the importer. An importer may only place a product on the EU market if it has a correct DPP associated with it: verify that the conformity procedure has been completed correctly, add its own data (name, address, EORI number) and show technical documentation to market surveillance authorities upon request.
In practice, the importer often bears full DPP responsibility when the non-EU manufacturer does not pick it up. Moreover, the ESPR provides that importers and distributors are considered manufacturers when they market a product under their own name or brand. It is therefore wise for importers to include DPP requirements in supplier selection and purchasing contracts now.
Distributor and retailer
Distributors and retailers have a duty of verification: verify that a DPP is present before reselling a product, keep the data carrier intact, and make the DPP accessible to customers, even in remote sales. If the DPP is missing, the product may not be resold.
How data flows through the chain
The data flow is bottom-up: each link adds information, from origins and certificates at the raw material to total environmental footprint and disassembly instructions at the final product.
Standards under development
To exchange DPP data in a structured way, the EU is working on standards to ensure interoperability across sectors and countries. The outlines are increasingly clear, although standardization is not yet complete. CIRPASS-2 (May 2024 to April 2027) validates DPP standards in practice through thirteen pilot projects in textiles, electronics, tires and construction products. The results directly feed into the CEN/CENELEC standardization that will set technical standards for the DPP system. Some examples of what that interoperability might look like are:
- GS1 Digital Link links product codes (such as a GTIN) via a URL structure to digital information, including the DPP. GS1 is not required by law, but is preferred by the European Commission as the basis for product identification.
- EPCIS 2.0, also from GS1, captures supply chain events (who, what, where, when) and, by supporting sensor data and certification data, is particularly suitable for dynamic DPP information.
However, as long as the Delegated Acts and standards are still under development, it is wise to work with open formats and flexible systems that remain adaptable when the final specifications appear.
Confidentiality
A common concern is that the DPP leads to unwanted disclosure of vendor data. The ESPR takes this into account through different levels of access. This is still to be determined, but one can think of the following set-up: consumers see basic information, professional parties detailed material data, recyclers disassembly instructions. Only market surveillance authorities have access to the full dataset. Competition-sensitive supplier data therefore need not be shared publicly.
Practical approach to chain cooperation
1. Start at tier 1 vendors
There is no need to map the entire chain at once. Start with the direct suppliers. They in turn must request data from their suppliers, and that responsibility lies with them.
2. Be specific in the request
A general message that DPP data is needed rarely produces useful results. Send a template with the specific data points needed, including the desired format. Most vendors are willing to cooperate, provided it is clear exactly what is being requested.
3. Integrate DPP into the procurement process.
Don’t wait for the requirement to take effect. Include DPP data requirements as part of the standard procurement process now: new suppliers provide the appropriate data from day one, existing suppliers are given a reasonable transition period, and DPP data becomes part of supplier reviews.
Moreover, the data required by the DPP is not exclusive to the DPP. In textiles, the information needs largely overlap with existing legislation such as REACH, the POPs Regulation and the Textile Labeling Regulation. The DPP thus offers the opportunity to build one structured data source that serves as a single source of truth for multiple legal obligations, rather than several separate data streams per regulation.
This article on DPP data collection provides concrete guidance on how to set up this process.
4.Exploit the opportunities behind the DPP
The DPP is often approached as a compliance requirement, but the transparency it enforces lays precisely the foundation for circular revenue models. Those who make information about repairability, lifespan and disassembly available digitally enable repair services, refurbishment or product-as-a-service models. And providing products and materials with a digital identity makes reuse logistically and administratively feasible in a way that it is not without traceability.
Wherever the DPP captures material data, it creates infrastructure for circular business models. The goal need not just be compliance, but can be the catalyst for circular innovation. This article takes a closer look at how those business models work in concrete terms.
5. Build incrementally
It is not necessary to collect all data from all suppliers at once. Start with the basic mandatory ESPR fields, expand to conditional and category-specific fields, and refine over time. The first delegated acts are expected during 2026, with DPP obligations eighteen to twenty-four months later. That seems ample, but building a reliable data flow from the chain takes months. Therefore, establish a process for periodic updates: a DPP is an ongoing process, not a one-time exercise.
Want to know what data to retrieve from suppliers?
The Empact DPP Tool shows which DPP data is already present, which information is missing and from which party it needs to be retrieved. Wondering how far along you are with the DPP? Start the free DPP analysis now.
Want to know how your organization can set up a DPP supply chain process or structure supplier requests? Contact Empact for a no-obligation discussion.