Digital Product Passports Are Coming in 2026: 10 Things Every Operations Leader Should Know

You're sitting in a Q1 planning session, and someone mentions "Digital Product Passports." Half the room nods knowingly. The other half is scrambling to Google it under the table. If you're in the second group: or worse, if you think you're in the first but haven't actually mapped out what compliance looks like for your operation: this is your wake-up call.

Digital Product Passports (DPPs) aren't a distant regulatory fantasy. Battery passports go live in February 2026. Textiles follow in July 2027. If your products touch EU markets, you're about to enter a compliance window that will fundamentally reshape how you manage data, design products, and coordinate with your supply chain.

Here's the kicker: most operations leaders are treating this like another checkbox exercise. They're not. DPPs represent a structural shift in how value chains operate: and the companies that get ahead of this now won't just comply, they'll gain a strategic advantage.

Let's break down what you actually need to know.

This Isn't Optional: It's EU Law

The Digital Product Passport is a mandatory requirement under the EU's Ecodesign for Sustainable Products Regulation (ESPR). It's not a voluntary sustainability initiative you can opt into when budgets allow. It's a legal obligation that dictates how you design products, manage data, and communicate with customers and regulators.

If you're manufacturing batteries, you have less than a year to comply. Textiles? Eighteen months after the delegated act was published in January 2026. Iron and steel products hit in October 2027. Consumer electronics, packaging, and construction materials are next in the queue.

Here's what's driving this: the EU wants to eliminate greenwashing, enable circular economies, and give consumers verified information about what they're buying. Your operations team is now the frontline enforcement mechanism for those policy goals.

Your Product Categories Are Rolling Out on a Staggered Timeline

The compliance timeline isn't universal: it's product-specific. Battery passports became effective February 2026. Textiles must comply by July 2027. Iron and steel products follow in October 2027. Additional categories including consumer electronics, packaging, and construction materials will roll out progressively.

Sound familiar? You're managing compliance across multiple product lines simultaneously, each with different deadlines, data requirements, and technical specifications. If you're a diversified manufacturer, you're effectively running parallel compliance projects with overlapping resource demands.

The 18-month compliance window starts after delegated acts are published and harmonized technical specifications are finalized. That clock is already ticking for some of your product categories.

Every Product Needs a Unique, Scannable Identifier

Each DPP is linked to a physical product via a scannable data carrier: typically a QR code, NFC tag, or RAIN RFID tag. This identifier is attached to the product, its packaging, or accompanying documentation. It serves as a persistent link to a secure digital repository containing verified product data.

Here's where it gets interesting: this isn't a one-time print job. The identifier must remain functional and accessible throughout the product's entire lifecycle. That means your tagging strategy needs to account for wear, damage, and replacement scenarios. It also means your database infrastructure must support long-term data retrieval: potentially decades for durable goods.

You're About to Become a Data Management Company

If you thought you were in the business of making products, think again. DPPs require you to collect, verify, and maintain extensive product data including:

• Materials and composition

• Manufacturing location and date

• Product labels and certifications

• Environmental impact metrics

• Maintenance manuals and service history

• Durability and end-of-life guidance

All of this data must be authentic, reliable, and verified. You're not just tracking serial numbers anymore: you're building a digital twin of every product you manufacture, complete with provenance documentation and lifecycle performance data.

Most operations leaders are underestimating the data collection burden. You'll need to coordinate with suppliers, logistics providers, and downstream partners to capture information at every stage of the value chain. If your current ERP and PLM systems aren't set up for this level of granularity, you've got a problem.

Machine-Readable and Interoperable Data Is Non-Negotiable

The DPP follows ISO/IEC 15459:2015 standards to ensure consistency and global interoperability. Information must be structured in a machine-readable format that can be easily maintained and updated throughout the product's lifecycle.

Let's talk about what this actually means: your data can't live in PDFs or spreadsheets. It needs to be structured, tagged, and accessible via APIs. Third parties: including regulators, customers, and recycling facilities: must be able to query and retrieve specific data points without manual intervention.

If you're running legacy systems that don't support structured data export, you're looking at a significant infrastructure upgrade. The good news? This is exactly the kind of challenge where AI and data integration platforms shine.

You're Responsible for Decentralized Database Infrastructure

Here's where most business leaders get confused: you must set up secure decentralized databases to store DPP data and control access for stakeholders throughout the product's lifetime. A backup copy must be available via a third-party product passport service provider, and the passport must remain accessible for at least the expected lifetime of the product.

Think about that last requirement. If you manufacture industrial equipment with a 20-year lifespan, you're committing to two decades of database maintenance, security updates, and access management. If your company gets acquired, restructures, or exits a market, those DPP obligations don't disappear.

You'll need to evaluate whether to build this infrastructure in-house, partner with a specialist provider, or adopt a hybrid model. There's no one-size-fits-all answer, but ignoring the question until 2026 isn't a strategy.

Supply Chain Transparency Becomes Your Competitive Advantage

DPPs enable real-time audit trails of asset and data flows, improving processes and information exchange throughout the value chain. You'll need to coordinate with suppliers to collect verified data at every stage of production and distribution.

Here's the strategic opportunity: companies that nail supply chain transparency won't just comply: they'll unlock operational efficiencies that competitors can't match. Real-time visibility into component sourcing, production milestones, and quality data creates opportunities for predictive maintenance, demand forecasting, and risk mitigation.

The companies treating DPPs as a compliance burden will build the minimum viable infrastructure. The companies treating them as a strategic enabler will redesign their value chains around verified, interoperable data. Guess which ones will dominate their markets in 2028?

The Regulatory Framework Allows Flexibility: But Not Everywhere

The ESPR doesn't define a single DPP format. Instead, it sets the framework with specific requirements introduced gradually by product category. However, unique product identifiers must be created and issued in accordance with established standards, and all DPPs must link to an EU digital product passport registry.

You have some latitude in how you implement the specifics, but the core architecture is non-negotiable. Use that flexibility wisely: design systems that exceed minimum compliance requirements and position you for future regulatory expansion.

International Coordination Is Necessary: and Complicated

The EU will extend support to partner countries and engage in dialogue to ensure joint collaboration with DPP regulations and infrastructure. That's the diplomatic language. Here's the reality: if you source components from Asia, manufacture in Europe, and sell globally, you're coordinating data collection across regulatory jurisdictions with different standards, timelines, and enforcement mechanisms.

Operations leaders should begin engaging with international partners now to align data collection and infrastructure. Waiting until delegated acts are finalized means you're negotiating supplier data-sharing agreements under time pressure with zero leverage.

You Need a Partner Who Actually Understands Value Chains

Most consultancies will sell you a compliance roadmap and disappear. That's not what you need. You need a partner who understands how data flows through complex value chains, how to integrate AI-driven automation without creating new bottlenecks, and how to build systems that scale as regulatory requirements expand.

At Value Chain Management, we've spent years helping mid-to-large organizations optimize operations around data, AI, and strategic resilience. DPP compliance isn't a standalone project: it's an opportunity to fundamentally improve how you manage information, coordinate with suppliers, and deliver value to customers.

If you're an operations leader staring down February 2026 deadlines and wondering where to start, let's talk. We'll help you build infrastructure that doesn't just comply: it positions you to win.

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Written by:

Mustafa Khan Managing Partner Value Chain Management

📍 128 City Road, London, EC1V 2NX, United Kingdom 📧 mk@valuechainmanagement.co.uk 📞 +44 20 3835 0822 | +44 77 7521 5464 🌐 www.valuechainmanagement.co.uk