Interview: practitioners on Digital product passports & traceability — what they wish they knew earlier

By 2030, the European Union will require Digital Product Passports (DPPs) for nearly every product category sold within its borders—affecting an estimated €14 trillion in annual trade flows. Yet according to a 2024 survey by the European Commission's Joint Research Centre, fewer than 12% of European manufacturers have implemented even pilot-level traceability systems capable of meeting the incoming Ecodesign for Sustainable Products Regulation (ESPR) requirements. "We thought we had time," admits one sustainability director at a major German automotive supplier. "What we discovered is that the technical infrastructure is the easy part. The real challenge is getting your entire value chain—from raw material extractors to end-of-life processors—aligned on data standards, incentives, and accountability."

This article synthesizes insights from practitioners across the European circular economy ecosystem who have spent the past three years implementing, failing at, and iterating on digital product passport systems. Their collective wisdom reveals a landscape far more complex than regulatory timelines suggest—one where stakeholder incentives frequently misalign, hidden bottlenecks emerge in unexpected places, and the difference between compliance theatre and genuine circularity often comes down to decisions made years before enforcement deadlines arrive.

Why It Matters

The Digital Product Passport represents the European Union's most ambitious attempt to operationalize circular economy principles at scale. Under the ESPR, which entered into force in 2024 and will see its first product-specific requirements in 2027, products ranging from batteries to textiles to electronics must carry machine-readable passports containing information about materials composition, repairability, recycled content, and carbon footprint. The regulation builds upon the Corporate Sustainability Reporting Directive (CSRD), which already requires large companies to disclose supply chain sustainability data, and the Battery Regulation, which mandated DPPs for EV batteries starting in February 2027.

The stakes are substantial. A 2025 analysis by the Ellen MacArthur Foundation estimated that full implementation of DPPs across priority product categories could unlock €600 billion in annual circular economy value by 2035, primarily through improved material recovery, extended product lifespans, and reduced virgin resource extraction. Meanwhile, the European Environment Agency reported that European waste management systems currently recover less than 35% of critical raw materials from end-of-life products—a figure that DPP proponents argue could double with proper traceability infrastructure.

However, the implementation pathway remains contested. The European Battery Alliance's 2024 readiness assessment found that 68% of battery manufacturers lacked the digital infrastructure to generate compliant passports, while a parallel study by DIGITALEUROPE revealed that interoperability between existing traceability systems—including competing blockchain platforms, legacy ERP systems, and proprietary supplier databases—remains the single largest technical barrier to DPP adoption. "The regulation assumes a level of data standardization that simply doesn't exist," notes a product compliance manager at a French electronics manufacturer. "We have 47 tier-one suppliers using 23 different data formats. Harmonizing that isn't a twelve-month project—it's a multi-year transformation."

Key Concepts

Digital Product Passport (DPP): A structured data carrier—typically accessed via QR code, NFC chip, or RFID tag—that provides standardized information about a product's composition, origin, environmental footprint, and end-of-life handling instructions. Under the ESPR framework, DPPs must be accessible to consumers, repair professionals, recyclers, and regulatory authorities, with different access levels for different stakeholder groups.

Sorting and Material Recovery: The process of separating waste streams into recyclable fractions. DPPs theoretically improve sorting efficiency by providing recyclers with precise material composition data, enabling automated identification and separation of valuable materials. Practitioners report that DPP-enabled sorting can increase material recovery rates by 15-40% compared to manual or spectroscopic identification alone.

Interoperability Standards: Technical specifications enabling data exchange between different DPP systems. The European Commission has designated CIRPASS, a consortium of over 30 organizations, to develop common standards. Key standards under development include GS1 Digital Link for product identification, EPCIS 2.0 for supply chain event data, and the Product Circularity Data Sheet (PCDS) format for environmental attributes.

Remanufacturing: The industrial process of restoring used products to original equipment manufacturer (OEM) specifications. DPPs support remanufacturing by providing access to repair manuals, spare parts catalogues, and product configuration data. The European Remanufacturing Council estimates that proper DPP implementation could expand the remanufacturing sector by €8.6 billion annually by 2030.

Extended Producer Responsibility (EPR): Regulatory frameworks requiring manufacturers to finance end-of-life collection and recycling of their products. DPPs integrate with EPR schemes by enabling fee modulation—adjusting producer fees based on actual product recyclability rather than product category averages. France's AGEC law, implemented in 2024, pioneered DPP-linked EPR fee modulation for electronics and textiles.

Benchmark KPIs: Standardized metrics for evaluating DPP system performance. Key indicators include data completeness rates (percentage of required fields populated), data accuracy (verified versus self-reported claims), passport accessibility (uptime and response times), and circularity impact (measured improvements in recycling rates, product lifespan, or material recovery).

What's Working and What Isn't

What's Working

Battery passport pilots demonstrate viability at scale. The Global Battery Alliance's Battery Passport initiative, operational since 2023, has enrolled over 15 major battery manufacturers and processed passport data for more than 2 million battery units. Participants report that standardized passport infrastructure reduced due diligence costs for battery materials by 23% while improving traceability coverage from 45% to 89% of supply chain mass. "The key was starting with a consortium approach," explains a programme manager at one participating manufacturer. "No single company could have built the data infrastructure alone, but shared investment made it feasible."

Textile sector achieves early wins through brand-led initiatives. Fashion brands including H&M, Zalando, and Inditex have implemented QR-code-based product passports across significant portions of their inventories. H&M's 2024 transparency report indicated that passport-enabled garments showed 31% higher customer engagement with recycling take-back programmes compared to non-passported items. The company attributes this to improved consumer awareness and simplified return logistics enabled by passport scanning at collection points.

Industrial equipment sees rapid ROI through predictive maintenance. Manufacturers of capital equipment—including Siemens, ABB, and Schneider Electric—report that DPP-style digital twins already deliver measurable returns through extended asset lifespans and optimized maintenance scheduling. Schneider Electric's 2024 sustainability report documented that connected equipment with comprehensive digital passports showed 28% longer operational lifespans and 35% reduction in unplanned downtime compared to non-connected equivalents.

What Isn't Working

SME onboarding remains critically bottlenecked. While large enterprises can absorb DPP implementation costs—estimated at €150,000-€500,000 for initial deployment—small and medium enterprises face disproportionate burdens. A 2024 survey by the European Small Business Alliance found that 73% of manufacturing SMEs lacked dedicated IT staff capable of implementing DPP systems, while 61% reported that existing business software was incompatible with emerging DPP standards. "The regulation treats a 15-person machine shop the same as Volkswagen," observes a compliance consultant specializing in SME transitions. "Without substantial technical assistance programmes, we'll see mass non-compliance or market exits."

Data verification infrastructure is underdeveloped. Current DPP frameworks rely primarily on self-reported data from supply chain participants, with limited third-party verification mechanisms. A 2024 investigative analysis by the Environmental Investigation Agency found that 34% of recycled content claims in European electronics products could not be substantiated through available documentation. "We're building passports on foundations of sand," warns a materials scientist involved in verification protocol development. "Without robust auditing, DPPs become greenwashing infrastructure rather than circularity tools."

Cross-border data governance creates friction. Products manufactured across multiple jurisdictions face conflicting data sovereignty requirements, particularly when supply chains extend beyond the EU. A 2025 legal analysis by the European Environmental Bureau identified 23 national variations in how Member States interpret DPP data storage and access requirements, creating compliance uncertainty for manufacturers operating across borders. Additionally, data sharing with non-EU entities—including recyclers and raw material suppliers—raises unresolved questions about GDPR applicability and trade secret protection.

Key Players

Established Leaders

SAP: The enterprise software giant has integrated DPP functionality into its Industry Cloud solutions, providing end-to-end traceability across manufacturing, logistics, and recycling operations. SAP's Green Ledger platform serves over 400 enterprise customers implementing sustainability data management.

Siemens: Through its Digital Industries division, Siemens offers DPP-ready product lifecycle management (PLM) solutions that connect design, manufacturing, and field service data. The company's Xcelerator platform provides standardized APIs for passport data exchange.

BASF: The chemical giant has pioneered material traceability through its reciChain platform, enabling chemical suppliers and customers to track recycled and bio-based content through complex transformation processes. BASF reports traceability coverage for over 8 million tonnes of materials annually.

Bosch: Bosch's manufacturing network has implemented DPP pilots across automotive components, power tools, and industrial equipment, with over 15 million passported units shipped in 2024. The company's connected manufacturing infrastructure provides a foundation for real-time passport generation and updating.

Philips: The healthcare and consumer electronics manufacturer has integrated DPP functionality into its circularity programmes, using digital passports to facilitate equipment refurbishment, spare parts provisioning, and end-of-life material recovery across its B2B and B2C product lines.

Emerging Startups

Circularise: This Dutch startup provides blockchain-based supply chain traceability specifically designed for circular economy applications. Circularise's platform enables anonymous data sharing that protects trade secrets while providing verified sustainability claims. The company has raised €12 million and works with clients including Porsche and Covestro.

iPoint-systems: A German sustainability software provider specializing in product compliance and environmental footprinting. iPoint's product passport platform integrates with existing ERP and PLM systems, reducing implementation friction for manufacturers. The company serves over 5,000 customers globally.

Materiom: UK-based Materiom maintains an open-source database of sustainable material recipes and specifications, providing foundational data that can populate DPP material composition fields. The platform has catalogued over 1,500 bio-based material formulations.

Tracifier: A Copenhagen-based startup offering AI-powered document verification for sustainability claims. Tracifier's technology can validate recycled content certificates, chain-of-custody documents, and third-party audit reports at scale, addressing the verification gap in current DPP systems.

Circularix: This Berlin-based company provides modular DPP infrastructure targeted at SMEs, offering simplified onboarding and pay-per-passport pricing models that reduce adoption barriers for smaller manufacturers.

Key Investors & Funders

European Investment Bank (EIB): Through its climate action financing programmes, the EIB has allocated €2.3 billion for circular economy infrastructure investments, including digital traceability systems. EIB-backed projects include several DPP pilot programmes in the battery and automotive sectors.

Horizon Europe: The EU's research and innovation programme has funded over €180 million in DPP-related research through calls including HORIZON-CL4-2024-TWIN-TRANSITION. Major funded projects include CIRPASS (DPP standards development), BATTERY 2030+ (battery passport infrastructure), and DigiPrime (digital transformation for circular manufacturing).

Breakthrough Energy Ventures: Bill Gates' climate investment fund has invested in several companies developing circular economy infrastructure, including Circularise and materials traceability platforms. BEV's portfolio companies collectively process sustainability data for over €50 billion in annual product flows.

SYSTEMIQ: This advisory and investment firm specializing in systems change has provided strategic funding and technical assistance to DPP initiatives, including the development of textile passport standards and policy recommendations for the European Commission.

Closed Loop Partners: The circular economy-focused investment firm has deployed over $500 million in circular infrastructure, including digital traceability systems for packaging and materials recovery. Their technology venture portfolio includes several DPP-adjacent startups.

Examples

1. Renault Group's Battery Passport Implementation (France/EU)

Renault became the first European automaker to deploy production-scale battery passports across its electric vehicle lineup in late 2024. The implementation covers the complete battery lifecycle from cell manufacturing through vehicle assembly, first-life use, second-life applications, and end-of-life recycling. Each passport contains over 90 data attributes including materials composition, carbon footprint, state-of-health metrics, and certified chain-of-custody documentation for critical minerals.

Results after 12 months showed measurable improvements: 67% of retired EV batteries were directed to verified second-life applications (up from 23% pre-passport), average battery refurbishment time decreased by 4.2 days due to instant access to configuration data, and recycled cobalt content in new battery production increased from 8% to 17% through improved material recovery. Implementation costs totalled €8.3 million across the battery supply chain, with projected five-year returns of €31 million through extended asset utilization and material value retention.

2. H&M Group Circular Fashion Passport (Sweden/EU-wide)

H&M's garment passport programme, launched across 23 European markets in 2024, embedded QR-coded passports in 340 million garment units—approximately 45% of the company's European sales volume. Passports provide consumers with fibre composition, care instructions, carbon footprint data, and garment-specific recycling guidance, while supplying downstream recyclers with material sorting information.

The programme achieved 2.8 million consumer passport scans in its first year, with scanning customers showing 47% higher participation in H&M's garment collection programme. Recycling partners reported 22% improvement in fibre sorting accuracy for passported versus non-passported garments. However, implementation challenges included supplier data quality issues (31% of passport fields initially populated with estimates rather than verified data) and technology access barriers in Eastern European markets where QR scanning rates were 64% lower than Western European averages.

3. Philips Healthcare Equipment Remanufacturing (Netherlands/EU)

Philips integrated comprehensive digital passports into its medical imaging equipment remanufacturing programme, covering CT scanners, MRI systems, and ultrasound devices sold across European healthcare markets. Passports track component-level lifecycle data including operating hours, calibration history, software versions, and replacement parts installed during service visits.

The passport-enabled remanufacturing programme processed 4,200 equipment units in 2024, achieving 94% component reuse rates (up from 71% pre-passport) and reducing average remanufacturing cycle time from 23 to 14 weeks. Philips estimates that passport-enabled remanufacturing avoided 12,400 tonnes of CO2 emissions and €127 million in virgin material costs during the year. Healthcare customers receive remanufactured equipment with validated performance histories, commanding 15-25% price premiums over non-passported refurbished alternatives.

Action Checklist

• Conduct a comprehensive data audit across your supply chain to identify existing data sources, formats, and gaps relative to ESPR requirements for your product categories
• Engage with industry consortia (such as CIRPASS, Catena-X, or sector-specific initiatives) to align your data standards with emerging interoperability frameworks before investing in proprietary solutions
• Establish contractual requirements with tier-one suppliers for DPP-compatible data provision, including data quality standards, update frequencies, and verification mechanisms
• Pilot DPP implementation on a limited product line to identify technical and organizational bottlenecks before regulatory deadlines require full-scale deployment
• Develop a tiered data access architecture that provides appropriate information to different stakeholders (consumers, repair professionals, recyclers, regulators) while protecting commercially sensitive details
• Integrate DPP data generation into existing manufacturing execution systems (MES) and enterprise resource planning (ERP) platforms rather than creating standalone passport systems
• Build relationships with downstream partners—including recyclers, remanufacturers, and second-life operators—to understand their data requirements and ensure passport information supports actual end-of-life processing
• Establish internal governance structures for DPP data quality, including clear ownership of data fields, validation procedures, and audit trails for regulatory compliance
• Allocate budget for ongoing passport maintenance, including data updates during product lifetime, system integration upgrades, and responses to evolving regulatory requirements
• Monitor EPR fee modulation developments in your primary markets, as DPP-linked eco-modulation of producer fees will significantly impact the economic case for passport investment

FAQ

Q: When will Digital Product Passport requirements actually become mandatory in the EU?

A: The ESPR entered into force in July 2024, but specific product requirements will phase in gradually starting in 2027. Batteries face the earliest deadline, with EV battery passports required from February 2027 under the Battery Regulation. Textiles, electronics, furniture, and construction materials will follow with product-specific requirements expected between 2028 and 2030. The European Commission is currently developing delegated acts specifying exact data requirements for each product category. However, practitioners recommend beginning implementation now, as building the necessary data infrastructure typically requires 24-36 months—meaning companies waiting for final requirements risk non-compliance at launch.

Q: How should companies handle trade secret concerns when sharing supply chain data through DPPs?

A: The ESPR framework includes provisions for protecting commercially sensitive information while enabling necessary transparency. Companies should implement tiered access controls, where consumers see aggregated environmental information while detailed compositional data is accessible only to authorized parties (repair professionals, recyclers, regulators). Technical solutions including zero-knowledge proofs and encrypted data sharing—offered by platforms like Circularise—enable verification of claims without exposing underlying supply chain details. Legal frameworks are still developing, but current best practice involves contractual agreements with data recipients specifying permitted uses and protection requirements.

Q: What infrastructure investments are essential for DPP readiness?

A: Core requirements include: (1) product identification infrastructure—unique identifiers (typically GS1-standard) for each product or batch, plus physical carriers (QR codes, RFID, NFC) enabling passport access; (2) data management systems capable of generating, storing, and updating passport content throughout product lifecycles; (3) integration middleware connecting existing business systems (ERP, PLM, MES) with passport platforms; (4) supplier data exchange capabilities for collecting and validating upstream information; and (5) consumer-facing access points (mobile apps, web portals) for passport retrieval. For SMEs, cloud-based passport-as-a-service solutions can reduce capital requirements, though ongoing subscription costs should be factored into product economics.

Q: How do DPPs integrate with existing EPR schemes?

A: EPR schemes in several Member States—particularly France under the AGEC law—are implementing "eco-modulation" of producer fees based on product sustainability attributes. DPPs provide verified data enabling this modulation, with products demonstrating higher recyclability, recycled content, or repairability receiving reduced fees. Integration requires: passport data meeting EPR scheme verification standards, technical interfaces with Producer Responsibility Organisation (PRO) reporting systems, and consistent product identification enabling fee assignment at SKU level. Companies implementing DPPs should engage early with their PROs to understand data requirements and potential fee reduction opportunities—which can provide positive ROI on passport investments.

Q: What happens if supply chain partners refuse to provide DPP-required data?

A: This represents one of the most significant implementation challenges practitioners face. Contractual mechanisms—including data provision requirements in supplier agreements and audit rights—provide baseline leverage, but enforcement can be difficult across complex, international supply chains. Practical approaches include: offering value propositions to suppliers (such as preferred vendor status or access to aggregated market data); using industry platforms that enable anonymous contribution; accepting calculated estimates for non-critical data fields with appropriate uncertainty documentation; and diversifying supply chains toward more transparent partners. Regulators recognize this challenge, and early guidance suggests enforcement will initially focus on data completeness rather than verification depth—though this tolerance will likely decrease over time.

Sources

• European Commission Joint Research Centre. "Digital Product Passport: Readiness Assessment Across European Industries." JRC Technical Report, 2024.

• Ellen MacArthur Foundation. "The Circular Economy Opportunity: Quantifying the Potential of Digital Product Passports." Foundation Research, February 2025.

• DIGITALEUROPE. "DPP Implementation Barriers: Technical Interoperability Study." Industry Report, November 2024.

• Global Battery Alliance. "Battery Passport Initiative: Year Two Implementation Report." GBA Publications, January 2025.

• European Environmental Bureau. "Cross-Border Data Governance for Product Passports: Legal Analysis and Policy Recommendations." EEB Research Paper, March 2025.

• CIRPASS Consortium. "Common Standards for Digital Product Passports: Technical Specification v2.0." European Commission Funded Research, 2024.

• Environmental Investigation Agency. "Verification Gaps in Circular Economy Claims: An Investigative Analysis." EIA Report, September 2024.