As an idea, the digital product passport (DPP) sounds pretty good. Imagine being able to simply scan a QR code on a product to discover all sorts of useful things about it:

  • A bar of chocolate’s passport could, theoretically, tell you where the cocoa beans were grown and whether the farm complied with Europe’s upcoming Deforestation Regulation; where and when the bar was made; in which countries it’s allowed to be sold; when it should be eaten; and the ways it contributes to the eater’s daily targets for sugar, fat, calories, and more.
  • An electric vehicle’s battery passport could tell you where the battery’s components were originally mined; what proportion of the lead, cobalt, lithium, and other elements was sourced from recycling (good) instead of mining (less good); and an indication of battery health, which might inform resale value.
  • An industrial robot’s passport could tell you where it was manufactured and link to product documentation, certified shipping and import paperwork, a full service history, and lists of the part numbers replaced during routine maintenance.

A DPP Is Associated With European Legislation But Is Internationally Relevant

The European Commission is enthusiastic about DPPs, and most discussion of these passports now tends to be in the context of new European rules like the Batteries Regulation and the Ecodesign for Sustainable Products Regulation (ESPR). These will require what the CIRPASS and CIRPASS-2 projects called “a massive issuing of DPPs” beginning in 2027, and both are discussed in a recent Forrester report, Embrace The Circular Economy To Make Manufacturing More Sustainable. Others, both inside and outside the European Union’s borders, also talk about “digital product passports,” “product passports,” or “battery passports.” They may — or may not — mean something that would technically meet the requirements of European regulators. Frankly it can be difficult to tell, and not just because the European Commission has punted almost all of the implementation detail to “applicable delegated acts” that haven’t been written yet. Article 9 of ESPR, for example, states that:

The information requirements shall provide that products can only be placed on the market or put into service if a digital product passport is available in accordance with the applicable delegated acts adopted pursuant to Article 4 and with Articles 10 and 11. The data in the digital product passport shall be accurate, complete and up to date.”

In other words, the Regulation requires companies to comply but doesn’t tell them how.

So What Is A DPP, Anyway?

While ESPR and the Batteries Regulation don’t manage to clearly describe what a DPP is, another Commission web page offers a reasonable summary:

“The DPP is designed to close the gap between consumer demands for transparency and the current lack of reliable product data. The DPP will include essential details such as a unique product identifier, compliance documentation, and information on substances of concern. It will also provide user manuals, safety instructions, and guidance on product disposal. By offering a detailed digital record of a product’s lifecycle, the DPP will enhance supply chain management, ensure regulatory compliance, and help companies identify and mitigate risks related to authenticity and environmental impact.”

The Batteries Regulation describes the high-level design aspirations for a DPP (usually called a “battery passport” in this context) without providing the sort of actionable detail needed to construct a functioning system of passports:

“To ensure that the battery passport is flexible, dynamic and market-driven and evolves in line with business models, markets and innovation, it should be based on a decentralised data system, set up and maintained by economic operators. To ensure the effective roll-out of the battery passport, the technical design, data requirements and operation of the battery passport should adhere to a set of essential technical requirements. Such requirements should be developed hand-in-hand with those for digital product passports required by other Union law concerning eco-design for sustainable products. Technical specifications, for which the Commission’s Connecting Europe Facility principles for the eDelivery Network should be considered, should be established to ensure the effective implementation of those essential requirements, either in the form of harmonised standards for which the references are published in the Official Journal of the European Union or, as a fall-back option, in the form of common specifications adopted by the Commission. The technical design should ensure that the battery passport carries data in a secure way which respects privacy rules.”

Give that to your favourite enterprise architect, ask them to build something robust, interoperable, or useful with it, and watch them start to cry.

Article 77 and Annex XIII of the Regulation provide a little more, including a (long) list of the classes of information that should be accessible by the public (carbon footprint data, etc.), by “persons with a legitimate interest” (parts numbers, disassembly instructions, etc.), and by “notified bodies, market surveillance authorities, and the Commission” (regulated test results, etc.). But there’s still a massive gulf between legislative aspiration and implementable code.

Demonstrators Put Theory Into Practice

The Battery Pass consortium has developed good content guidance and technical guidance. Together, these capture consortium members’ view on turning the Battery Regulation’s aspiration into something implementable. To prove their point, the Battery Pass consortium also offers a demonstrator which aggregates battery data from various stakeholders to show what a human-readable representation of a Battery Passport might look like. Siemens offers a similar interpretation. Battery Pass consortium member Circulor worked with Volvo to deliver the “world’s first EV battery passport” for Volvo’s EX90 cars earlier this year. The Global Battery Alliance also offers demonstrators, but with a more global flavour. All of these, and DPP demonstrators like those from CIRPASS-2, help to show what’s possible and highlight the areas where standardization work is still needed.

Standards Bodies Push The Market Closer To Interoperable DPPs

The ICT Standardisation Observatory and Support Facility in Europe (StandICT.eu) produced a report on ‘The Landscape of Digital Product Passport Standards’ back in 2023. It listed “186 international and European standards from recognised standardisation bodies… and a further 78 standards from other standards developing organizations,” but the report’s foreward still mentioned that the authors do not claim to offer a “complete” list!

The European Commission has asked the European Committee for Standardisation, the European Committee for Electrotechnical Standardisation, and the European Telecommunications Standards Institute to identify standards “as regards digital product passports in support of Union policy on ecodesign requirements for sustainable products and on batteries and waste batteries.” This work is due to conclude by 31 December 2025, which should provide firms with a little more guidance on which standards to choose.

This month, the Clean Energy and Smart Manufacturing Innovation Institute (CESMII), the Labs Network Industrie 4.0 (LNI 4.0), the Digital Twin Consortium, the ECLASS e.V., the Industrial Digital Twin Association (IDTA), the OPC Foundation (OPCF), the VDMA and the ZVEI used the Smart Production Solutions (SPS) trade show in Germany to announce a joint effort to combine “the best aspects of the Asset Administration Shell, OPC UA and other related technologies” in support of delivering DPPs.

Service Providers Pull The Pieces Together For Their Customers

It’s already easy to find vendors that offer DPP solutions and services on the market. Startups like Circularise, Circulor, Kezzler, and Path.Era are making a business out of DPP. The Bosch Semantic Stack is being positioned to support key automotive use cases like Catena-X’s work on digital product passports, and the Siemens Battery Passport builds on Siemens’ existing participation in Catena-X, the Global Battery Alliance, and SiGREEN. Today, each of these companies adopts standards where they can, but they must still make lots of local implementation decisions to deliver a system that works. Hopefully, the formalization of standards and good practice will eventually reduce unnecessary differences between these implementations.

Pay Attention: 2027 Is Not That Far Away

Beginning on 18 February 2027, all LMT (light means of transport such as e-bikes, etc.) batteries, industrial batteries with a capacity greater than 2kWh and electric vehicle batteries will require a battery passport if they’re to be sold within the EU. The first tranche of ESPR passports will also begin to appear in 2027, when a “minimal and simplified DPP” will be required for textiles, and an “environmental vehicle passport” will be required as part of the new Euro 7 regulation. Many other product categories will need DPPs before the end of the decade.

Demonstrators, proofs of concept, and other collaborations between small groups of like-minded companies certainly help illustrate the art of the possible. But to deploy DPPs at scale we will need to grapple with bad data, conflicting priorities, contradictory interpretations of vague rules, and bad actors with every incentive to downplay limitations in their own products while emphasizing similar weaknesses in their competitors’. This is not an academic exercise; it’s a data-based underpinning for a system of reporting, compliance, and financial penalties that will have far-reaching implications. The rules need to be clear, and the standards need to be robust. If the Commission’s deadlines are to be met, both they and other stakeholders in the ecosystem can’t afford to wait.

As always, if you have your own perspectives to share, please schedule a briefing and tell us all about them. If you’re a Forrester client and want to discuss (or challenge) my thinking on this topic, please schedule an inquiry.