The Silent Conversations Around DPP: 10 Topics We Can't Ignore

The Digital Product Passport (DPP) has emerged as a game-changer for numerous industries in the EU, spanning batteries, textiles, detergents, construction materials, tires, electronics, and more. But what exactly is DPP, and why is it generating so much conversation?

Stepping Back: The “What, Why, and How” of DPP

While still in development, the DPP concept revolves around creating a digital-twin for products, capturing all details from sourcing to components. The ultimate goal? Enabling circularity and achieving a neutral carbon footprint by 2050 in the EU. However, reaching this goal is proving complex and somewhat chaotic, with various working groups – from material suppliers and manufacturers to standard organizations and solution providers – still figuring out how to align their approaches.

Topics on the Table… and Those Still Missing

Yes, many topics are being discussed: in-scope categories, data collection for passports, data assurance, interoperability, the Eco-design for Sustainable Products Regulation (ESPR), Environmental and Social Governance (ESG), and more. Yet, what about the critical issues still flying under the radar? Below is my list of the top "non-discussed" DPP topics:

1. Interoperability and Integration

Interoperability is foundational and currently on the agenda, yet the scope is vast, and numerous elements remain unaddressed. DPP will require data exchange throughout the supply chain. Are we truly prepared for this?

• Standards: Some elements, like unique identifiers and data security, are in discussion, driven by CENELEC, JTC24, and other standards bodies. Yet, questions linger. Will GS1 standards for data exchange (e.g., EPCIS) be applied, or will alternative APIs or solutions like GS1 Data Link take precedence?
• Data Carriers: Which scanning technologies will we adopt? QR codes, data matrix, GS1-128, NFC, RFIDs? Textiles, for instance, may lean toward RFID, while other industries might prefer QR or data matrix codes. Industry standards here are still evolving.
• Data Consistency: For interoperability, data recipients must understand the incoming format. With complex supply chains, managing proprietary formats won’t be feasible, so the importance of standardized formats is paramount.
• Cross-industry Interoperability: Ensuring that systems across industries can share data effectively remains challenging, given that sector-specific standards are still under development.

2. Data Collection and Data Management

Master Data – covering Product MD, Location MD, Customer MD – will require a single source of truth. In many companies, Master Data is scattered across various systems (ERP, WMS, CRM, etc), often without clear governance. Defining accountability and governance for Master Data is crucial for smooth data collection and long-term efficiency.

3. Solution Performance

With potentially billions of uniquely identified products, can existing technologies and repositories handle the data retrieval and exchange needs of DPP? Testing for performance and peak data loads will be essential.

4. Serialization (Unique Identifiers)

Each product will need a unique identifier, but a standardized approach across sectors has yet to be finalized. Without harmonized coding standards, the costs of implementation and data exchange could increase dramatically.

5. Global Repositories

Should there be centralized or decentralized repositories? Some large firms favor decentralization, citing high data volumes and the need for data privacy. But if decentralization wins out, integration challenges will follow.

6. Strategy on Downstream Supply Chain

DPP will require traceability from raw materials to the final product, a particularly tough feat in industries with globalized supply chains. DPP itself isn’t a traceability tool, but circularity can’t happen if downstream supply chains aren’t fully integrated into DPP regulations, such as with the Battery Passport. Distributors, wholesalers, and recyclers will need to be onboarded formally and invited to share their unique insights and capabilities.

7. Cross-border Regulatory Compliance

Companies with global supply chains must ensure their DPPs comply with both EU and international regulations. Imagine a product manufactured in the U.S., imported to Poland, then sold in Germany and Turkey. How do we manage compliance and reporting here, and who is liable if something goes awry? Without cross-border data management guidelines, violations are likely when products cross international boundaries.

8. Data Ownership and Privacy

The DPP will involve a vast amount of data exchange across the supply chain, including environmental impact and product lifecycle data. However, there’s little clarity on who owns this data and how privacy concerns, especially with sensitive business data, will be addressed. There are many questions around this, like how to access the data from the Supply Chain? what about data privacy? Who will access to this data and how will it be used? How do we avoid that sensitive data is being accessed by competitors? What is the role of GDPR into this? Is Blockchain still an option not only in terms of data privacy and access but also in terms of energy consumption? Questions remain about how blockchain will integrate with existing supply chain systems and the extent to which the DPP will require real-time data updates. Independent and neutral bodies will need to be set to verify and assure data.

9. Cost of Compliance

Industries are aiming for “cheap solutions”, but they need to understand that even if there are cost-efficient license models, there is a big chunk of the cost into the consulting part: what is the current state and what needs to be done (As-Is vs To-Be), data situation, processes to be kept/changed, high production volumes which will require more sophisticated implementations, SC complexity, customization needs and others. The more solutions that exist and that will be develop, the more competitive price tags will exist. Let’s take in mind that the industries are only talking about software solutions, but for implementing serialization and scanning, the big part of the investment will go into hardware components.? Compliance costs for small and medium-sized enterprises (SMEs) are a major concern, without sufficient financial support or phased implementation, these companies might struggle to meet DPP requirements, especially given the investment needed for new infrastructure, personnel, and digital systems.

10. BAU (Business as Usual) Running Costs

With DPP, companies will face increased operational costs, including serialized production, maintenance, ongoing training, and the need for new data retrieval and reporting processes. Support costs (from basic helpdesk support to advanced levels, L1 to L3) will also rise. Moreover, regulators will likely require industry contributions to establish and maintain verification bodies. Therefore, selecting the right solution aligned with company size and volumes is critical, as is a Total Cost of Ownership (TCO) analysis to anticipate the impact on business-as-usual operations.

Moving Forward: A Call to Action

These topics are critical for the DPP discussion, especially given that the first regulations are set for late 2025. Preparing data according to standards and establishing clear governance now will save time during implementation and reduce consulting costs in the long run.

Building trust in the supply chain is essential, yet this trust must be grounded in technically capable, reliable solutions.

We have compliance regulatory precedents, such as the DSCSA in pharma and the EUTPD for tobacco. Why not learn from these examples to refine best practices and avoid repeating known pitfalls? The existing regulatory framework can provide valuable insights for DPP stakeholders as they move forward.

What are your thoughts? Which additional topics would you prioritize?

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