The European Union has taken a leading role in shaping a variety of data and AI regulations. One of its most recent initiatives, the Ecodesign for Sustainable Products Regulation (ESPR), extends this regulatory momentum into the manufacturing sector. Under this new regulation, manufacturers and their partners will be required to create and maintain digital product passports—comprehensive, full life-cycle digital records that capture the raw materials, components, and attributes of every manufactured product. 

Although the ESPR has officially passed into law, enforcement across most industries isn’t expected until sometime between 2027 and 2030. Even so, the outlined requirements are already evolving from a regulatory initiative into a market expectation. That means now is the time to move beyond simple understanding what the digital product passport (DPP) is and start applying it strategically across your business to drive value and readiness.

Early lessons from DPP implementation

DPP pilots and industry workshops are still in the preliminary stages across most industries, with limited official results or standardized trends available. However, there are some early observations and emerging data points that are already revealing important insights.

For example, early-stage pilots show that compliance involves far more than just generating documentation. Companies are encountering challenges such as inconsistent material data, limited life-cycle traceability, and the need to fundamentally rethink how product information is shared across supply chains.

Additional early observations

Prioritizing sustainability from the start: Early DPP adopters are reimagining product development by embedding sustainability throughout the process—not as a final check, but as a core design principle. This includes incorporating sustainable practices at every stage: ideation, design, material sourcing, production, shipping, recycling, and beyond.

Rethinking supplier collaboration: Traditional supplier relationships often fall short of DPP demands. In response, early adopters are pushing for greater transparency and consistency, including new data-sharing agreements and more collaborative exchange models across the supply chain.

Moving beyond dated data storage and siloed systems: Many companies still manage critical product data in spreadsheets or siloed systems, leading to inconsistent data and overhead. These legacy approaches create significant barriers to meeting DPP’s requirements for open, persistent, and searchable data formats.

Investing in structured platforms and contextual technology: Pilot participants are focusing on solutions like standardized material classification systems, digital thread architectures, and integrated product life-cycle management (PLM) environments. These approaches support a more structured and contextual option to managing product data.

Establishing end-of-life data tracking infrastructure: These pilots are helping manufacturers realize what “full” data life-cycle tracking means. Comprehensive data tracking strategies are required for DPP throughout the end-to-end product life cycle, even if a product is discontinued or the company goes out of business. Finding long-term data collection and storage solutions is becoming a new imperative.

Identifying and addressing infrastructure gaps: Existing data systems often lack the scalability and longevity needed for DPP compliance. As a result, companies are exploring third-party repositories and long-term data management solutions to bridge these gaps and ensure readiness.

Enabling DPP with PLM and digital thread technologies

A digital thread is a connected, contextualized flow of product data and assets spanning all relevant domains of the product life cycle. Unlike traditional enterprise resource planning (ERP) or back-office systems, a modern digital thread provides real-time visibility and traceability—even for data updates from third parties such as suppliers, logistics providers, or repair technicians. The goal is simple yet powerful: Regardless of a person’s role in the product life cycle, they can access a unified view of all relevant product data, including component specifications, material origins, shipment history, stakeholder interactions, product condition, repairability, and more.

To support DPP readiness, digital threads—enabled by modern PLM platforms—integrate and orchestrate data from ideation through production, delivery, recycling, and end of life. When properly implemented, a digital thread ensures that any update made across the life cycle is automatically reflected across the system within the proper product configuration context. This enhances accuracy, transparency, and traceability, especially in areas where manufacturers may have had limited visibility in the past.

To implement a digital thread strategy that’s compatible with DPP compliance requirements, companies must invest in a purpose-built digital thread or modern PLM platform, or upgrade their existing systems. These platforms must support real-time updates, data continuity, configuration management, and cross-platform interoperability. Ideally, such systems are cloud-based, ensuring that all stakeholders—regardless of location—have immediate access to the most current product data.

Preparing for the future of digital product passports

Monitor the regulatory landscape around the globe

Don’t limit your preparation to the EU’s current DPP regulations. It’s equally important to monitor global conversations and anticipate what similar regulations may emerge elsewhere. Building proactive knowledge of DPP and similar regulations will keep you ahead of competitors and better prepare you to scale your infrastructure accordingly.

Your research should span multiple regions and industries, with particular attention to your own sector and those of your suppliers and partners. Look at expert, vetted sources as well as the general chatter among your peers. Even informal conversations can highlight potential best practices for future compliance.

Clean and collect updated product data

Review and evaluate current data practices, ideally through a comprehensive data audit. This will help you assess whether you already have the information required for DPP compliance, or whether you need to adopt new data collection methodologies to fill critical gaps. For example, many companies lack detailed data on material composition for components sourced from third-party suppliers.

Ongoing data cleaning and collection will help you identify errors and gaps in your own data and in all data that touch your product life cycle. To support this effort, consider investing in modern data infrastructure, such as a cloud-based PLM platform that enables a digital thread, to streamline data intake, ensure consistency, and improve accessibility across your ecosystem.

Upgrade IT infrastructure for interoperability

Complying with DPP requirements may require significant updates to your current IT systems. As mentioned earlier, it’s possible that some ERP or PLM platforms fall short when it comes to integrating with digital threads or supporting the level of data interoperability that DPP demands. It’s important for organizations to consider upgrading to scalable solutions designed to adapt quickly and integrate seamlessly with both internal and external systems. Prioritizing flexibility and interoperability now will help future-proof your infrastructure as regulatory expectations continue to evolve.

Embrace evolving standards for material classification

As companies scale their DPP efforts, one challenge gaining attention is the lack of standardized material classifications. New frameworks are emerging to define material characteristics in consistent, shareable ways—laying the foundation for centralized or federated material libraries.

The construction sector, for example, uses platforms like mindful MATERIALS to centralize verified data on product sustainability. Manufacturers can draw from these examples to create similar systems, improving data accuracy, speeding compliance, and enabling more efficient collaboration across the value chain.

The evolving role and benefits of the DPP

Digital product passports are rapidly evolving from a regulatory requirement in the EU into a strategic asset that delivers real business value. This shift is enabling not only greater transparency and traceability, but also new, more sustainable business models such as “product as a service.” Forward-thinking manufacturers are beginning to recognize that complying with DPP standards does more than ensure compliance. It can strengthen customer trust with increased transparency and sustainability, drive innovation for new design, optimize opportunities based on product- and component-level insights, and improve supply chain flows and efficiencies with traceability and data sharing across stakeholders. 

Ultimately, embracing DPP practices—especially by leveraging a digital thread infrastructure—can benefit your organization even if compliance isn’t yet mandated in your region or industry. Being an early adopter of smarter, more sustainable processes sends a clear message to customers, partners, and investors alike: You’re committed to creating responsible, future-ready products.