One data format for all product sustainability regulations – the Digital Product Passport as a Single Source of Truth

This article is a guest contribution. The views expressed are those of the authors and do not necessarily reflect the position of osapiens. It reflects the regulatory status as of August 2026 and provides general information rather than legal advice.

PPWR, ESPR and other product-specific requirements mean extensive data work, often in siloed systems. The Digital Product Passport can make an important contribution to solving this problem: by centrally structuring relevant product data, leveraging it for various compliance requirements, and improving internal processes. We'll show how this works at our free Product Sustainability Lab on September 24, 2026 in Cologne.

By Lina Dawid, Timo Ernst and Julia Urbauer, Sustainable AG Unternehmensberatung

Regulation on a treadmill

The Corporate Sustainability Reporting Directive (CSRD) is barely digested before the Ecodesign for Sustainable Products Regulation (ESPR), the Packaging and Packaging Waste Regulation (PPWR) and the Digital Product Passport (DPP) come knocking. For sustainability managers and product developers, this often feels like a regulatory sprint with no finish line: each regulation its own project, its own budget, its own data format.

On closer analysis, however, the requirements are less isolated than they first appear. Many product-related requirements draw on the same data: material composition, recyclability, carbon footprint and proof of origin. The real challenge, then, is not to report even more, but to meaningfully structure existing data and deploy it across the relevant systems, processes and process steps.

Current starting point

That this data perspective is worth taking right now is also reflected in the regulatory calendar: since July 20, 2026, the European DPP Registry including its testing environment has been live – the central infrastructure through which product identifiers and metadata will be registered in the future, while the actual product information remains decentralized with companies. The DPP is thus leaving the drawing board and becoming technical reality.

A general DPP obligation does not yet follow from this; implementation will be phased. Which data is specifically required for which product group is determined, for ESPR product groups, by the respective delegated acts under the ESPR and, for other product groups, by standalone EU legal acts. For ESPR delegated acts, a minimum period of 18 months between entry into force and the start of application generally applies, with justified exceptions possible. But those who wait until all details are finalized are wasting time: an early technical test is already worthwhile now. For companies, this means: prepare data models and master data now.

The overlap lies in product data

The various requirements intersect at a decisive point: product data. The ESPR requires, depending on the product group, information on materials and product characteristics. The PPWR concerns packaging, for instance regarding recyclability or hazardous substances. A Product Carbon Footprint (PCF) makes the climate impact of a product measurable.

The common denominator of these product-related requirements is reliable data along the value chain. Those who build it cleanly once can answer multiple regulatory questions simultaneously – and avoid siloed solutions for each requirement.

Specifically: the recycled content share of packaging that you document for the PPWR is the same data point you need for the PCF of your products and that can later appear in the DPP. Maintaining it in three separate Excel sheets means doing the same work three times.

The following visualization illustrates this connection: a shared, sufficiently granular data foundation can serve multiple requirements simultaneously, because different standards, regulations and frameworks draw on similar data points and nodes.

The DPP bundles product information, not the entire regulation

Sustainability compliance remains a cost driver as long as we treat it as pure reporting. Those who instead integrate it into existing processes and systems turn it into a genuine value lever – for synergies, more efficient decisions and better products.

The Digital Product Passport is not simply the next reporting obligation. It makes product information digitally available in a structured manner along the value chain. The standards and the technical solution are merely the form – what matters is which data you capture, how you use it to activate your value chain, how reliable that data is, and who maintains and provides it.

Those who set up the DPP as a shared data foundation can use product data multiple times. Procurement, product development, sales and sustainability then work with the same information at different levels of aggregation, rather than each maintaining their own lists.

An example: your product development team assesses whether an alternative polymer improves recyclability. Procurement needs the same information for supplier assessment. The sustainability team uses it for the Product Carbon Footprint; communications uses it for substantiated product claims. If this data resides in one place, a large part of cross-departmental coordination becomes redundant. A supplier request can be set up once, rather than reformulated for each regulation. And when materials change, only one source needs updating. At the same time, decision quality improves at every single step.

What companies should do now

Five concrete steps:

1. Clarify applicability: Map your product groups to the relevant requirements. The starting point is the EU Commission's ESPR Work Plan 2025–2030: it lists which product groups are prioritized and when. Additionally, it's worth reviewing the product-specific PPWR requirements, for instance on recycled content and recyclability. Record which data already exists, at what quality and granularity, and where you depend on suppliers.
2. Map overlaps: Take a specific product group and lay out the key data points alongside it: material composition, recycled content share, recyclability, origin and carbon footprint. Mark which department currently maintains the information and in which system it resides.
3. Start with a real case: Choose a product facing regulatory pressure in the coming years. Use it to test whether data can be captured, updated and shared with reasonable effort – and at which nodes in procurement, product development and sales processes would need to be adapted.
4. Define KPIs and accountability: Assign a responsible person or function for each data point. Clarify who approves data, how changes are documented, and when suppliers must update information. Determine how you will make progress measurable.
5. Review outcomes: In addition to data quality and progress on relevant indicators, measure process quality – for instance, whether supplier requests are answered faster, whether duplicate data maintenance is eliminated, and whether product development and sustainability are working from the same data foundation.

The DPP is not an end in itself

The DPP does not have to start from zero. It can be the occasion to build product data in a way that works across multiple processes – in procurement, product development, sustainability reporting and, later, in customer interaction. The initial effort creates the prerequisite for the same information not having to be searched for, verified and entered repeatedly.

Once this data foundation works, subsequent steps become possible: material data from suppliers can be integrated more regularly, information from use and maintenance flows back into product development, and take-back or refurbishment can be organized more effectively. All these steps are possible – what matters is taking the first one today: with a specific product and a few relevant data points.

Want to take the first step or dive deeper?

On September 24, 2026, Sustainable AG Unternehmensberatung invites you to the Product Sustainability Lab in Cologne: a full day of hands-on product regulation, with interactive workshops on Product Accounting, sustainable supply chains and circular business models. Plus a live demo of the Digital Product Passport in the DPP oLab with our partner osapiens.

Limited to 30 participants. Free of charge. Register now for free (German)