DPP in the Supply Chain: Implementing It Securely on a Global Scale

For industrial companies that source products internationally, the key DPP challenge lies behind the QR code: The necessary product data must be reliably available across countries, supplier tiers, and different IT systems. This transforms the supply chain into a compliance infrastructure—and its data quality into a prerequisite for access to the EU market.

Why the DPP Is Changing the Supply Chain

DPP obligations apply to covered products regardless of whether they were manufactured in the EU or imported. The primary responsibility for ensuring the accuracy and completeness of the information lies with the economic operator who places the product on the EU market. For imported products, registration may also be relevant for customs clearance and release.

A supplier outside the EU does not automatically become the party responsible to European authorities as a result. However, they do become an indispensable source of data. Missing or unverifiable information regarding materials, substances, origin, or environmental performance can therefore affect the entire end product.

What Supplier Data Is Required

The final required fields depend on the specific product-related regulation.

Nevertheless, companies should already prepare their supplier processes for the following data categories:

• Unique product, component, and supplier identifiers,
• Materials, ingredients, and required documentation,
• Origin, production, and environmental information,
• certificates and compliance documentation,
• version, change, and approval statuses.

Not all information needs to be public. Access rights, trade secrets, and data required by regulatory authorities should already be separated within the data model.

Four Decisions for Management

Responsibility: A centralized DPP governance framework must integrate procurement, compliance, product management, and IT.

Supplier Management: Data formats, documentation, updates, and audit rights should be included in contracts and onboarding processes.

Architecture: PIM, MDM, ERP, and PLM should not only store data but also make it available through traceable sources and interfaces.

Prioritization: Pilot programs should focus on products with complex supply chains, high import ratios, or immediate regulatory relevance.

International Standards Instead of Isolated Solutions

The DPP must function across company, industry, and national boundaries. The ISO/IEC JTC 5, established in 2026, is therefore developing the foundations for cross-system and cross-sector interoperability. At the same time, the central EU DPP registry has been operational in a test environment since July 20, 2026.

Companies should therefore avoid building isolated national solutions and instead prioritize open identifiers, standardized interfaces, and interchangeable data models.

The DPP transforms international supplier data into a strategic production factor. What matters is not having as much data as possible, but rather clear accountability, verifiable quality, and interoperable processes. Executive management teams should now jointly establish supplier governance and product data architecture—without anticipating any product-specific requirements that are still pending.

FAQ

1    Does the DPP also apply to products from non-EU countries?

Yes. What matters is whether the product is placed on the EU market, not the country of manufacture. The responsible economic operator is the one in charge.

2    Can responsibility be contractually transferred to suppliers?

Supply contracts can address data obligations and recourse. However, this does not relieve the economic operator of its regulatory responsibility toward authorities.

3    What data should companies start collecting now?

Priority should be given to product identity, materials, substances, origin, verifiable evidence, and relevant environmental information. The specific fields required are determined by the applicable legal act.

4    Does the DPP replace other supply chain obligations?

No. It organizes product-related information and evidence but does not replace independent due diligence, customs, or reporting obligations.

Bibliography

• Europäisches Parlament und Rat: Verordnung (EU) 2024/1781, 13.06.2024, EUR-Lex, abgerufen am 23.07.2026.
• Europäische Kommission: Digital Product Passport, laufend aktualisiert, abgerufen am 23.07.2026.
• Europäische Kommission: Economic operators, o. D., abgerufen am 23.07.2026.
• Europäische Kommission: The DPP Registry is now live, 20.07.2026, abgerufen am 23.07.2026.
• ISO: ISO/IEC JTC 5 – Digital Product Passport, 2026, abgerufen am 23.07.2026.
• DIN/DKE: Globale Standards für den Digitalen Produktpass, 20.04.2026, abgerufen am 23.07.2026.