Data story: Key signals in circular design & product-as-a-service

Digital product passports (DPPs) are moving from concept to compliance requirement. The EU's Ecodesign for Sustainable Products Regulation mandates DPPs for batteries starting 2027, with textiles and electronics following by 2030. Five data signals reveal the scope of change — and what product teams should prioritize now.

Quick Answer

Digital product passports will fundamentally change how products are designed, sold, and managed. Battery DPPs launch in February 2027 with 90+ mandatory data fields. Textiles DPPs follow in 2027-2028. Electronics requirements are being drafted for 2030. Companies that build DPP infrastructure now will capture advantages in compliance readiness, secondary markets, and customer relationships through product-as-a-service models.

Signal 1: EU Battery Regulation Sets the Template

The Data:

• Compliance date: February 2027 for industrial and EV batteries
• Data fields required: 90+ attributes per battery
• Unique identifier: QR code or similar digital link on every battery
• Data access: Tiered — public, authorized users, and notified bodies
• Update frequency: Lifecycle events trigger mandatory updates

What It Means:

The EU Battery Regulation creates the most detailed product data requirements ever mandated. Every industrial and EV battery sold in the EU must carry a digital passport with:

Required Data Categories:

• Manufacturer and responsible economic operator information
• Battery model, type, chemistry, and manufacturing location
• Carbon footprint declaration (kg CO₂e per kWh)
• Recycled content percentages (cobalt, lead, lithium, nickel)
• Performance data (capacity, expected lifetime, state of health)
• Supply chain due diligence information
• Dismantling and recycling instructions
• End-of-life handling requirements

The Technical Architecture:

Battery passports must be accessible via standardized QR code scanning. Data resides in decentralized storage with access controls based on user type. Interoperability standards (developing) will enable data exchange across systems.

The Next Signal:

Watch for state-of-health (SoH) data standards. Accurate SoH assessment enables second-life applications (grid storage, backup power) — a market projected to reach $15 billion by 2030.

Signal 2: Textiles DPP Requirements Taking Shape

The Data:

• Timeline: Requirements expected 2027-2028 (delegated acts in development)
• Product scope: Clothing, footwear, furniture textiles, mattresses
• Expected data fields: 50-70 attributes per product
• Microfiber disclosure: Shedding rates likely mandatory
• Durability metrics: Expected lifetime, wash cycles, color fastness

What It Means:

Textiles represent the pilot sector for consumer-facing DPPs. Draft requirements suggest focus areas:

Likely Required Data:

• Fiber composition with origin traceability
• Manufacturing facilities and social compliance
• Chemical substances (PFAS, formaldehyde, heavy metals)
• Water and energy consumption in production
• Microfiber shedding classification
• Durability test results and expected lifetime
• Repairability information and available parts
• Recycling instructions and material recovery potential

Industry Implications:

The fashion industry — historically opaque about supply chains — faces significant disclosure requirements. Brands will need to trace materials through multiple tiers of suppliers, many in regions with limited digital infrastructure.

The Next Signal:

Harmonization with France's existing textile environmental labeling (eco-score) and broader EU textile strategy. Expect carbon footprint and water usage metrics to become prominent.

Signal 3: Electronics DPP Framework Emerging

The Data:

• Timeline: 2030 for smartphones, tablets, computers; other electronics to follow
• Repairability scores: France's mandatory scores influencing EU approach
• Battery requirements: Already covered under Battery Regulation from 2027
• Spare parts availability: 5-10 year minimum requirements anticipated
• Software update period: Disclosure of support timeline likely mandatory

What It Means:

Electronics DPPs will emphasize repairability and longevity, building on existing Right to Repair frameworks:

Expected Data Categories:

• Repairability index (0-10 scale) with component-level scoring
• Available spare parts and pricing
• Repair manual accessibility
• Software update commitment period
• Security update guarantee duration
• Disassembly and repair instructions
• Recycled and recyclable material content
• Hazardous substance declarations

Design Implications:

Products designed for repairability score higher. Modular design, standard fasteners, and accessible components become competitive advantages rather than cost considerations.

The Next Signal:

Extension to appliances, HVAC equipment, and industrial machinery. The Ecodesign Regulation framework enables DPP requirements for any product category.

Signal 4: Product-as-a-Service Adoption Accelerating

The Data:

• Market growth: 22% CAGR for PaaS models (2020-2025)
• B2B adoption: 40% of industrial equipment sold as service (up from 15% in 2015)
• Consumer adoption: 8% of durable goods acquired through subscription/rental
• Retention economics: 2.5x customer lifetime value in PaaS vs. one-time purchase

What It Means:

Digital product passports enable product-as-a-service models by providing the data infrastructure for lifecycle management:

PaaS Model Requirements:

• Asset tracking: Location and custody chain
• Condition monitoring: Real-time performance data
• Maintenance history: Complete service records
• Usage metering: Basis for pay-per-use pricing
• End-of-term processing: Refurbishment, redeployment, or recycling

Sector Leaders:

• Lighting: Signify (Philips) "Light as a Service" — 50M+ connected points
• Industrial equipment: Rolls-Royce "Power by the Hour" — engines sold as thrust
• Office furniture: Steelcase and Herman Miller subscription programs
• Consumer electronics: Grover, Raylo device subscriptions

The Next Signal:

Integration of DPP and PaaS data systems. Companies managing products as services already collect lifecycle data — DPP requirements formalize and standardize what leaders already do.

Signal 5: Technical Infrastructure Investment Scaling

The Data:

• DPP pilot funding: €75 million in EU-funded pilots (2022-2025)
• Blockchain platforms: 15+ consortia developing DPP infrastructure
• Standards development: GS1, ISO, and W3C working on interoperability
• Implementation cost estimates: €5-50 per product for full DPP (varying by complexity)

What It Means:

The technical architecture for DPPs is being built now through pilots and standards development:

Infrastructure Components:

• Unique identifiers: GS1 Digital Link enabling QR-based access
• Data carriers: QR codes, NFC tags, RFID for different use cases
• Decentralized storage: Blockchain-backed for immutability; cloud for accessibility
• Access management: Tiered permissions for different stakeholders
• Interoperability: APIs enabling data exchange across systems

Key Pilot Projects:

• CIRPASS: EU-funded consortium developing cross-sector DPP standards
• Battery Pass: German consortium piloting battery passport infrastructure
• TextileGenesis: Blockchain traceability for textiles (already operational)
• EPREL: EU product registry providing technical foundation

The Next Signal:

Emergence of DPP service providers offering compliance-as-a-service. SMEs without internal technical capacity will rely on platforms providing data collection, storage, and access management.

Action Checklist for Product Teams

• Map current product data systems and identify gaps versus DPP requirements
• Assess supply chain visibility — can you trace materials to origin?
• Implement unique product identifiers if not already in place
• Engage with industry pilots (CIRPASS, Battery Pass) for early learning
• Evaluate DPP platform options — build vs. buy vs. consortium participation
• Design new products with DPP data collection integrated from concept
• Train procurement and quality teams on supplier data requirements
• Consider PaaS business model opportunities enabled by lifecycle data

FAQ

When do DPP requirements become mandatory? Battery DPPs are mandatory February 2027. Textiles requirements are expected 2027-2028. Electronics by 2030. Other product categories will follow based on delegated acts under the Ecodesign Regulation.

What technical infrastructure is required? At minimum: unique product identifiers (QR codes), data storage system with API access, and integration with supply chain data sources. Full implementation may require blockchain-backed storage for verified claims.

How much will DPP compliance cost? Estimates range from €5 per product for simple consumer goods to €50+ for complex industrial products. Costs decrease with scale and automation. Early movers benefit from system optimization before compliance deadlines.

Do DPP requirements apply to products sold outside the EU? Only products placed on the EU market require DPPs. However, major brands are implementing DPP systems globally for operational efficiency and to meet evolving requirements in other jurisdictions.

Sources

1. European Commission. "Ecodesign for Sustainable Products Regulation." Official Journal of the EU, 2024.
2. European Commission. "Battery Regulation Technical Standards." EC JRC, 2024.
3. CIRPASS Consortium. "Digital Product Passport Pilot Results." CIRPASS, 2024.
4. Ellen MacArthur Foundation. "Digital Product Passports: Unlocking the Circular Economy." 2024.
5. GS1. "Digital Link Implementation Guidelines for DPP." GS1, 2024.
6. McKinsey & Company. "Product-as-a-Service: Business Model Evolution." 2024.