In our previous article, we explored what the Digital Product Passport means strategically for businesses in batteries, textiles, and construction. This follow-up gets into the practical details: what data you need to collect, how to structure your implementation, and what pitfalls to avoid.
What a DPP Actually Contains
Before diving into implementation, let’s clarify what you’re building toward. A Digital Product Passport is a structured digital record accessible via a QR code, NFC chip, or RFID tag. The EU requires this data to be machine-readable, based on open standards, and compatible with the Commission’s central registry.
While specific requirements vary by product category, most DPPs will need to include:
Product identification: A unique identifier following ISO/IEC 15459:2015 standards, manufacturer details, model and batch information, and production facility location.
Compliance documentation: Declaration of conformity, technical documentation, relevant certifications, and information about substances of concern.
Environmental data: Carbon footprint calculations, recycled content percentages, and durability indicators. For batteries, this extends to electrochemical performance data and supply chain due diligence documentation.
Lifecycle information: Installation guidance, maintenance requirements, repair options, and end-of-life handling instructions including disassembly and recycling procedures.
Access controls: Different stakeholders get different levels of access. Consumers see public information. Authorities and authorized actors access restricted compliance data. The system must handle both.
Sector-Specific Implementation
Batteries
Battery companies face the earliest mandatory deadline: February 18, 2027. The good news is that the Battery Regulation provides the clearest specifications of any sector. The Battery Pass consortium has published detailed technical standards, and DIN DKE SPEC 99100 outlines core data attributes.
Start here:
Map your current data collection against required fields. Most battery manufacturers already track much of this information internally. The gap is usually in structuring it for external sharing and connecting it to individual product identifiers.
Calculate your carbon footprint per battery model and manufacturing plant. This requires methodology alignment with EU specifications. Get this right early because it feeds into everything else.
Establish supply chain due diligence documentation. This means tracing raw materials, particularly cobalt, lithium, and nickel, back through your supply chain with verified sourcing data.
Build your unique identifier infrastructure. Every battery needs a QR code linking to its passport. This sounds simple but requires integration between production systems, labeling equipment, and your DPP platform.
Textiles
Textile companies have slightly more runway, with requirements likely becoming mandatory around mid-2028. However, the complexity of global textile supply chains means you need that extra time.
Start here:
Audit your supply chain visibility. Textiles typically involve dozens of manufacturing steps across multiple countries. You need to identify every facility in your chain and establish data-sharing agreements with suppliers.
Focus on material composition first. Document fiber content, country of origin for each material, and any recycled content percentages. This foundational data supports everything else.
Prepare for the ban on unsold goods destruction. The ESPR prohibits destroying unsold textiles, and this connects directly to DPP tracking. You need systems that can account for every item’s lifecycle outcome.
Consider your labeling strategy. Physical products need data carriers that link to digital passports. Decide whether you’re using QR codes on care labels, NFC in hang tags, or other approaches. Test durability through washing cycles.
Construction Products
Construction operates under the revised Construction Products Regulation, with a phased approach tied to harmonized standards updates. GWP declarations are already required for certain products as of January 2026.
Start here:
Determine which product families apply to you. The CPR’s Annex VII defines 36 product families. Identify where your products fall and monitor which harmonized standards are being updated first.
Prioritize Environmental Product Declarations (EPDs). The CPR builds on EN 15804 standards for lifecycle assessment. If you don’t have EPDs for your products, start that process now. It feeds directly into your DPP data.
Align with BIM requirements. Construction DPPs are designed for compatibility with Building Information Modeling systems. Your product data structure should support seamless integration with digital building projects.
Plan for 25-year data retention. The CPR requires passport data to remain accessible for 25 years after a product ceases production. This has significant implications for your data infrastructure and service provider relationships.
Common Implementation Mistakes
Treating DPP as a one-time project. Passports require ongoing updates throughout the product lifecycle. Build systems that support dynamic data, not static snapshots.
Starting with technology before data. Many companies buy platforms before understanding what data they have and what they’re missing. Audit your current data landscape first.
Underestimating supplier cooperation. Your DPP is only as good as your supply chain data. Begin supplier conversations early. Some will need significant support to provide data in the required formats.
Ignoring access control complexity. Different data for different stakeholders isn’t a nice-to-have. It’s a regulatory requirement. Build this into your architecture from the start.
Waiting for final specifications. The core requirements are clear enough to begin. Waiting for every detail to be finalized means starting when competitors are finishing.
A Practical Timeline
Now through Q2 2026
- Conduct a data gap analysis. Compare what you currently collect against likely DPP requirements for your sector. Identify the gaps.
- Establish supplier data agreements. Begin conversations with key suppliers about data sharing. Some relationships will take months to formalize.
- Select and implement a DPP platform. Look for solutions that can evolve with regulations, integrate with your existing systems, and scale with your operations.
Q3 2026 through Q4 2026
- Run pilot projects on a subset of products. Work out operational issues before full rollout. Test the entire flow from data collection through QR code scanning.
- Train your teams. DPP touches procurement, manufacturing, quality, sustainability, and IT. Everyone needs to understand their role.
- Validate data quality. Run audits on your pilot data. Regulators and customers will eventually verify this information.
2027
- Battery companies go live with mandatory passports in February. Use lessons learned to refine processes.
- Textile and construction companies complete pilots and prepare for their mandatory phases.
- Monitor regulatory updates. Delegated acts will continue to refine requirements. Stay connected to industry groups and standardization bodies.
Finding the Right Partner
DPP implementation is genuinely complex, but it doesn’t require enterprise-scale budgets or multi-year consulting engagements. The key is finding a partner who understands both the regulatory landscape and the practical realities of running a business.
At DPPA, we’ve designed our platform specifically for this challenge. We work hands-on with customers to implement DPP solutions that fit their operations, scale with their growth, and evolve as regulations clarify. Our involvement in Standard Norway’s DPP standardization committee means we’re tracking requirements at the source.
Ready to start your implementation? Contact us to discuss your specific situation and timeline.
DPPA AS develops Digital Product Passport solutions for EU regulatory compliance, serving businesses across construction, textiles, and battery industries.