From Compliance to Innovation: How Digital Product Passports Will Redefine the EU Supply Chain

As Europe moves toward a circular economy, one of the most transformative regulatory shifts on the horizon is the introduction of Digital Product Passports (DPPs). From 2027, these data-rich companions will start to accompany physical goods across their lifecycle - recording where they came from, what they contain, and how they can be reused or recycled.

For businesses across technology, manufacturing, and supply chains, the implications are profound. The DPP is not just an administrative tool, it represents a fundamental rethinking of how products and data interact. For IP professionals, it opens up new questions about data ownership, interoperability, and patentable innovation.

From label to ledger: the regulatory landscape

The European Commission’s  Ecodesign for Sustainable Products Regulation (ESPR), which entered into force on 18 July 2024, outlines the role of Digital Product Passports in achieving a circular economy in the EU. The upcoming DPP framework will require companies to create structured, verifiable records of product composition, environmental performance, and provenance.

The first sector in line is the battery industry, where digital passports will become mandatory from February 2027 under the EU Battery Regulation. Other categories, from electronics to textiles and construction materials, are expected to follow later in the year. The passport requirement will be extended to more sectors, including furniture, tyres, mattresses, packaging, plastics and chemicals over the following 3-5 years. The underlying goal is ambitious yet clear: to make the product economy transparent, traceable, and ultimately more sustainable.

What is a Digital Product Passport?

A DPP is a digital record that collects, stores, and shares key data about a product’s lifecycle. Instead of relying on paper documentation or proprietary databases, it provides a centralised (or, in some cases, distributed) repository accessible to relevant stakeholders. Manufacturers, suppliers, recyclers, regulators, and even consumers can consult the passport to understand how a product was made, what materials it contains, and how it can be responsibly managed at end of life.

In short, the DPP aims to close the information gap that has long hindered circularity, transforming opaque supply chains into networks of verifiable, interoperable data.

Battery passports: illuminating the supply chain

The battery industry will be the first to experience this new transparency in action. Batteries, particularly those used in electric vehicles and large-scale storage, involve complex chemistries and multi-tiered supply chains that make traceability challenging.

The battery passport seeks to change that by providing a living record of each unit’s chemistry, capacity, carbon footprint, and state of health. By doing so, it promises to break down long-standing information silos and enable more efficient recycling and reuse. Second-life applications, such as reusing EV batteries for stationary storage, could be greatly facilitated if accurate performance and degradation data travel with the product.

Companies like Technovative Solutions Ltd. (TVS) are already positioning themselves at the forefront of this transition. TVS develops sustainability and circularity solutions that align closely with the DPP vision, helping manufacturers collect and manage the data necessary for compliance and for building consumer trust.

Plastics: tracing every polymer

Plastics remain one of the thorniest challenges in circular economy policy. The sheer diversity of polymer types, additives, and applications makes recycling and provenance tracking notoriously difficult. DPPs could provide a breakthrough by linking each batch or product to its material identity and journey.

An early glimpse of this approach can be seen in SeaSweepers’ re:Trace platform, which uses blockchain and IoT technologies to trace plastic waste from ocean recovery through to reprocessing. This kind of system could underpin future DPP implementations for plastics, ensuring that data on polymer composition, recyclability, and environmental impact travels securely along the chain. For brands facing mounting pressure to substantiate sustainability claims, the DPP could soon become a powerful ally.

Medical devices: a passport to patient safety

In the medical sector, traceability is not only an environmental issue but a matter of patient safety. DPPs offer a way to bring unprecedented visibility to the design, manufacture, and maintenance of medical devices.

As Wipro has observed, DPPs could create a single, reliable source of truth for device data - covering everything from component sourcing to software updates. This level of transparency becomes particularly valuable during recalls. A recent IQVIA report on digital technology in device recalls highlights how connected data systems can drastically reduce the time required to identify and retrieve affected products. A DPP-based ecosystem could make recall processes faster, more accurate, and less costly, while simultaneously strengthening regulatory compliance.

In such a data-driven environment, innovation in how device information is captured and secured could itself become a source of intellectual property: from secure tagging systems to cloud-based traceability architectures.

Challenges and opportunities on the road ahead

Implementing DPPs will not be without difficulties. Gathering and validating granular data across global supply chains is complex, and many companies may hesitate to share sensitive information for fear of losing competitive advantage. Technical barriers, such as the lack of interoperability standards and the difficulty of verifying supplier-reported carbon data, will also need to be addressed. Moreover, the question of who is responsible for maintaining a product’s digital identity after its first life - during reuse, remanufacturing, or recycling - remains open.

Yet the opportunities are equally significant. The emergence of DPP systems will spur innovation in data management, secure communication, and product identification technologies. Forward-looking companies are already exploring patent protection for enabling technologies such as encrypted data exchange protocols, digital twin frameworks, and AI-based verification systems. Beyond patents, there will be scope to develop proprietary platforms, trademarks, and licensing models built around DPP compliance and analytics.

For innovators in this space, the message is clear: while regulation will drive adoption, IP strategy will define differentiation. Filing early, strategically, and with interoperability in mind could make all the difference when the world’s products start to travel, digitally, under their own credentials.

In the years to come, the humble passport may no longer be just a travel document, but the heartbeat of every product we design, use, and recycle.

This blog was co-authored by Darena Slavova and Chloe Flower.