Getting Ahead of the DPP Delegated Acts: Mapping and Collecting Product Data Now

Many companies plan to start Digital Product Passport (DPP) preparation once the delegated acts for their product group is adopted. Waiting for the technical guidance seems sensible, since that is where the exact data requirements are set. 

However, companies don’t often realize that much of the framework is already in place. The EU DPP Registry went live on July 20, 2026, and the first product delegated act, for iron and steel, is expected in Q4 2026. So, while the exact data requirements are still open, companies already know enough to begin the two tasks that take the longest: mapping their product data and collecting what’s missing from suppliers. 

What the ESPR has already set 

Every digital product passport, whatever the product group, is built on the same foundation. The Ecodesign for Sustainable Products Regulation (ESPR) lays it out in Articles 9 to 14: 

• Each product gets a unique identifier and a data carrier, and each passport is registered in a central EU registry.
• Different audiences, from consumers to market surveillance authorities, see different levels of detail.
• A back-up copy with an independent service provider keeps the passport available even if the company behind it stops trading. 

Much of the technical groundwork is in place too. The registry rules have applied since August 6, 2026. The first six of eight harmonized DPP standards were referenced in the EU’s Official Journal in July 2026, and the Commission plans the implementing decision on the remaining two for November 2026. One requirement already holds for every product group. Passport data has to be accurate, complete, and up to date (Article 9(1)), which makes the quality of your underlying product data the real starting point. 

The ESPR also expects passports to build on information companies already report. Under Annex III, each delegated act can draw in data and documents that other EU laws require, such as Declaration of Conformity (DoC) or information on substances. 

What each product-specific delegated act under the ESPR adds is the product-specific layer. It decides which data points a passport carries, whether it applies per model, batch, or individual item, and who can update what. Once it is adopted, companies usually get at least 18 months before the requirements apply (Article 4(4)). 

How waiting shortens DPP preparation before the February 18, 2027 battery deadline 

Batteries show what this looks like in practice. Under the EU Battery Regulation, passports become mandatory on February 18, 2027, for three groups: 

• batteries for light means of transport (LMT) such as e-bikes and e-scooters
• industrial batteries above 2 kWh
• electric vehicle (EV) batteries 

That date was fixed back in 2023. The rules on who may access restricted passport data, such as a battery’s state of health, are still being finalized. The Commission published its draft implementing act on October 19, 2026, with feedback open until November 16, and plans adoption for Q4 2026. That leaves less than three months between the final access rules and the deadline. Companies that waited for every detail would have very little time to set up their passports. 

The Commission’s own guidance points in the same direction. In its Battery Passport FAQ, it answers the question of how industry should prepare when standards or guidance arrive shortly before implementation. 

Other ESPR product groups could face a similar situation. Eighteen months sounds like plenty until you factor in supplier requests, follow-ups, corrections, and system changes, often across several product lines at once. 

In KPMG’s DPP readiness survey of more than 70 European organizations, published in early 2026, only 19% described themselves as well-prepared for the DPP, meaning they had assigned roles and responsibilities, while 53% said they were just getting started. 

Two DPP data tasks with the longest lead times

Neither of these tasks has to wait for a delegated act, and the results stay useful once it arrives. 

Map the data for one representative product 

This is often where most of the time goes. Product data tends to be spread across ERP, PLM, procurement, and compliance systems that were not built to share it. It’s stored in different formats and owned by different teams. Bringing one product’s attributes together means aligning those teams and reconciling values that don’t always match. 

Not every gap has to be filled from scratch. Other EU regulations already require some of this data, so parts of it may already sit in your compliance records, often with supplier processes in place to collect it. 

*These records might not match the delegated act’s requirements exactly. They give you existing inputs to build on within the passport. 

Pilot supplier data collection 

Data a supplier already holds can still take as long to obtain as data that doesn’t exist yet. The KPMG survey reflects this. Collecting data from suppliers was the most frequently cited implementation challenge, named by 31% of respondents. 

This is why data collection pilot projects can help companies understand where they stand: 

• Send real requests for your representative product and a few others, across different suppliers and tiers.
• Then track how many respond, how long it takes, where gaps recur, and who needs extra support.
• If you already collect supplier data for EUDR, CBAM, or substance declarations, start from those contacts and channels instead of opening a new one.
• The results give you a realistic basis for planning collection across your full supplier base. 

Both tasks also need one clear owner. In the KPMG survey, 23% of respondents said responsibility for DPP implementation had not yet been assigned. 

Structured and timely DPP preparation with osapiens 

Whatever each delegated act ends up specifying, a product-level gap map and real supplier response data will remain useful. They also give you concrete criteria for choosing a DPP platform, so the decision follows your requirements rather than the other way around. 

The osapiens HUB for DPP brings together product master data, supplier responses, and compliance records, and connects to EU systems such as TRACES, SCIP, and EPREL. For the full 90-day preparation plan and five questions to ask your DPP vendor, download the DPP Implementation guide. 

To go further, join one of our upcoming DPP events. 

• Digital Product Passports for Textiles: What Brands and Manufacturers Should Prepare, a webinar with Accenture on November 26, 2026
• What Powers the DPP?, a DPP oLAB event on December 2, 2026
• Or visit the DPP oLAB in Cologne