DPP for Manufacturers Guide

Introduction: The Next Era of Product Transparency

The Digital Product Passport (DPP) represents one of the most transformative initiatives under the European Union’s Ecodesign for Sustainable Products Regulation (ESPR). It aims to make every product a source of verifiable sustainability data—ensuring transparency from raw materials to recycling.

At its core, the DPP is a digital identity for products. It connects stakeholders—manufacturers, importers, regulators, and consumers—through structured, interoperable information. For industries navigating ESG reporting, circular economy mandates, and complex global supply chains, the DPP will soon be indispensable.

The Framework: ESPR and Legislative Foundations

The foundation of the DPP lies within Regulation (EU) 2023/1542, part of the Ecodesign for Sustainable Products Regulation (ESPR). The ESPR mandates that all products entering the EU market must carry a digital record containing standardized information categories:

1. Identification and Contact Information

Every product’s DPP must specify the manufacturer, importer, and economic operator, including unique identifiers such as:

• EORI numbers (Economic Operator Registration and Identification)
• Global Trade Identification Numbers (GTIN)
• Unique Operator and Facility IDs

2. Product and Operational Information

The passport includes technical and compliance data:

• Declarations of conformity
• User manuals, safety instructions, and technical documents
• TARIC and commodity codes

3. Product Lifetime and Sustainability Data

Manufacturers must disclose metrics such as:

• Durability, reparability, and recyclability
• Maintenance and end-of-life guidelines
• Design elements that reduce environmental impact

4. Material and Substance Information

Transparency extends to substances of concern, including:

• Concentrations, locations, and CAS identifiers
• Safe-use instructions and disassembly data

5. Environmental Impact and Efficiency

This encompasses energy and resource efficiency, carbon footprint, recycled content, and waste generation profiles.

The EU Battery Regulation (2023/1542) is not just another compliance mandate; it is the pilot implementation of the Digital Product Passport (DPP) concept in real-world industries. Batteries are a complex, high-impact product group with deep environmental, safety, and sourcing implications—making them the ideal test case for the European Union’s broader sustainability vision.

Under the new regulation, every industrial, automotive, and electric vehicle battery sold in the EU must have a Digital Battery Passport by 2027. This digital record consolidates data on composition, origin, environmental footprint, and circularity—accessible across the entire supply chain.

Key Information Layers Within the Battery Passport

1. General Battery and Manufacturer Information
   Each passport includes identifiers such as the manufacturer’s Global Trade Identification Number (GTIN), EORI, and facility identifiers. It also specifies product type, chemistry, and regulatory compliance details, creating a verified digital identity for every battery.
2. Material Composition
   The DPP demands transparency over critical raw materials (like lithium, cobalt, and nickel), their sources, and concentrations. Hazardous substances must be reported along with their CAS numbers and hazard classifications under the CLP Regulation. This ensures traceability and risk management across the entire lifecycle.
3. Carbon Footprint and Lifecycle Data
   The passport records the total CO₂ equivalent per kWh and breaks it down across stages—raw material extraction, manufacturing, distribution, use, and end-of-life. It also includes links to public carbon footprint studies, supporting transparency and benchmarking across manufacturers.
4. Circularity and Resource Efficiency
   Metrics on recycled and renewable content, safety measures, and end-of-life management are mandatory. Each DPP outlines take-back programs, collection networks, and consumer roles in proper recycling. This ensures batteries remain part of a closed-loop circular system rather than ending as hazardous waste.

🧠 Technical Foundations: From Product ID to Knowledge Graph

The CIRPASS Project (2024), funded by the European Commission, lays the technical groundwork for DPP interoperability. It envisions a decentralized and product-centric data ecosystem, ensuring that product information can be shared securely and meaningfully across jurisdictions and industries.

Core Design Principles

• Legacy Support:
  The system is designed to integrate existing enterprise databases, ERP systems, and industry data vocabularies to avoid costly overhauls.
• Flexibility:
  As sustainability regulations evolve, DPP frameworks must adapt dynamically—supporting both mandatory and voluntary data sets.
• Ease of Deployment:
  The architecture leverages established web and data technologies (like RDF, URIs, and HTTP), reducing barriers to implementation.
• Decentralized Control:
  Each participant—manufacturer, importer, or recycler—retains control of their own data. There is no central database, enhancing resilience and security.
• Product-Centric Model:
  Every product’s unique identifier (UID) becomes the anchor of its data graph, ensuring consistency and traceability throughout its lifecycle.

The DPP as a Knowledge Graph

The DPP is not merely a static database; it’s a living, interconnected data graph. Each product is represented as a Named Graph, allowing information to be queried, updated, and linked to other datasets globally.

Following Tim Berners-Lee’s Linked Data Principles (2006), this system ensures:

1. Unique URIs serve as permanent product identifiers.
2. HTTP access to product data for machines and humans alike.
3. Rich, contextual metadata connecting sustainability, compliance, and performance data.
4. Seamless integration with other regulatory and industry databases.

This semantic approach transforms the DPP into a web of product knowledge—a foundation for AI-driven sustainability analytics and real-time supply chain visibility.

⚙️ Integration and Validation: SHACL and the EU Registry

Data integrity is the cornerstone of trust in the DPP system. To achieve this, the EU employs SHACL (Shapes Constraint Language)—a powerful mechanism that defines how DPP data should be structured and validated.

How It Works

• Automated Validation:
  SHACL templates define the expected structure, relationships, and constraints of DPP datasets. Manufacturers can automatically validate their submissions before uploading them.
• Pre-Registration Testing:
  Responsible Economic Operators (REOs) can test their DPP data for completeness and accuracy, minimizing rejection rates and manual reviews.
• EU Registry Integration:
  Once validated, DPPs are stored in the EU DPP Registry, where Market Authorities and Customs Offices can verify compliance instantly. This automation cuts bureaucracy while enhancing regulatory precision.

The result is a trust framework—where compliance verification becomes real-time, auditable, and digitally certified.

The Digital Product Passport (DPP) operates through a layered digital infrastructure that enables products to carry and communicate verified sustainability and compliance data.
At the heart of this system are mechanisms that connect physical identifiers (like QR codes or RFID tags) to digital data repositories—using either HTTP-based links or Decentralized Identifiers (DIDs).

Both architectures aim to make product data discoverable, interoperable, and verifiable, but they differ in how that data is hosted, secured, and accessed.

🏷 1. Scanning Devices: The Gateway to Digital Identity

Consumers, recyclers, regulators, and manufacturers access DPP data through scanning devices such as QR codes, barcodes, or RFID tags printed or embedded on products.
These devices extract the Product Unique Identifier (UID)—the key that links a physical object to its digital record.

Scanning can occur through:

• Smartphones
• Industrial scanners or IoT sensors
• Embedded readers in manufacturing or recycling facilities

Once scanned, the UID is transmitted to an Internet-Connected Device (ICD), which interprets and routes the query to the correct digital destination.

💻 2. Internet-Connected Devices (ICDs): Translating Physical IDs into Digital Access

ICDs—such as smartphones, IoT gateways, or industrial systems—convert a Product UID into a Uniform Resource Identifier (URI) using the GS1 Digital Link Standard.
This conversion allows data to be accessed seamlessly via the web, connecting the physical product to its digital passport through a single click or scan.

ICDs serve as the translator between product identifiers and the broader DPP infrastructure, ensuring that users—whether consumers or authorities—can instantly retrieve accurate, structured product data.

🔁 3. Resolvers and Data Access Points

Resolvers are the bridge between identifiers and the data sources that store DPP information.
They ensure that a scanned or entered UID leads to the correct digital record.

There are two main resolver types:

• REO Resolvers: Managed by Responsible Economic Operators (manufacturers or importers), hosting their own DPP data.
• EU Default Resolver: Operated by the European Commission as a backup registry, ensuring continued access even if the original company ceases operations.

Resolvers thus maintain continuity, accessibility, and reliability across the DPP ecosystem.

🌍 4. Two Coexisting System Architectures: HTTP vs. DID

The European DPP framework supports two complementary architectures for implementing these data flows—each with unique advantages and roles in the broader ecosystem.

4.1 The HTTP-Based DPP Architecture

The HTTP model leverages the existing web infrastructure and standards, making it the first practical implementation of DPPs under the Ecodesign for Sustainable Products Regulation (ESPR).

🔧 How It Works

• The Product UID (e.g., GTIN or serial number) is converted into a URI via the GS1 Digital Link.
• This URI points to a resolver, which directs users to the DPP information hosted by the manufacturer, importer, or the EU Registry.
• The system works with standard QR codes, RFID tags, and barcodes, ensuring immediate usability.

🧩 Key Components

• Scanning Devices: Capture the UID from product markings.
• ICDs: Translate the UID into a URI and fetch DPP data.
• Resolvers:
• REO Resolver — Maintained by manufacturers or importers.
• EU Default Resolver — Maintains access if REOs go offline.
• EU Registry: Acts as a central node for validation templates and compliance oversight.

✅ Advantages

• Built on mature, global web standards.
• Easy integration with e-commerce and customs systems.
• Low implementation cost and high scalability.

⚠️ Limitations

• Centralized dependencies on resolvers or registries.
• Limited data sovereignty for operators, as data access is mediated through central nodes.

4.2 The DID-Based (Decentralized Identifier) DPP Architecture

The DID-based model, developed under the CIRPASS project and W3C standards, represents the next evolution of DPP technology. It replaces centralized identifiers with self-sovereign, blockchain-backed identities that ensure security and transparency by design.

🔧 How It Works

• Each product or organization is assigned a Decentralized Identifier (DID)—a globally unique URI.
• This DID resolves to a DID Document, containing verification keys, service endpoints, and metadata that define access permissions.
• Information exchange occurs through Verifiable Credentials (VCs), digitally signed attestations verifying the authenticity of sustainability claims or product attributes.

🧩 Key Features

• Security and Availability: Distributed ledgers eliminate single points of failure.
• Self-Sovereignty: Companies retain full control over their data and credentials.
• Portability: DIDs and VCs work across different ecosystems and borders.
• Trust and Integrity: Cryptographic proofs validate every transaction or claim.

✅ Advantages

• Tamper-proof traceability throughout the supply chain.
• Privacy by design, allowing selective data sharing.
• Resilience through distributed networks.

⚠️ Limitations

• Requires new digital infrastructure and governance models.
• Complex implementation, still maturing through EU-led pilots (e.g., CIRPASS).

⚖️ 5. Comparing the Two Architectures

The two systems are complementary rather than competitive. The HTTP approach serves as the foundation for early implementation, while the DID model introduces a future-proof, decentralized layer that ensures trust, resilience, and self-sovereignty.

🔄 6. The Hybrid Future: Integrating HTTP and DID Frameworks

The EU’s long-term vision is a hybrid DPP ecosystem that combines the accessibility of HTTP systems with the security and autonomy of DIDs.
In this model:

• The HTTP URI provides the entry point for users.
• The DID record behind it ensures authentication, immutability, and cryptographic verification.

Such a structure offers the best of both worlds—maintaining ease of access for consumers and regulators, while embedding decentralized trust and privacy protection for economic operators.

This harmonized dual-architecture approach aligns with the EU’s digital sovereignty goals and supports the circular economy vision through secure, transparent, and interoperable product data systems.

The Digital Product Passport is more than a digital label—it’s the DNA of sustainable industry. By merging regulatory compliance, data science, and decentralized trust, it creates a unified language for sustainability.

At ComplyMarket, we provide cutting-edge Product, Sustainability, and Material Compliance Management Systems that embed DPP capabilities at their core. Our platform supports companies in:

• Generating and managing DPP datasets automatically
• Validating data against SHACL and ESPR requirements
• Integrating seamlessly with supply chain and PLM systems

Through intelligent automation and secure architecture, we help organizations not only comply—but lead in the new era of digital sustainability.