On November 27th, 2025 the second DPP Event themed “Digital Product Passport & Traceability: Enabling Sustainability through Effective Policy” successfully took place, welcoming participants at the Centre for European Policy Studies (CEPS), Place du Congrès 1, 1000 Brussels.
This milestone event is part of an ongoing series organized by the Institute of Communication and Computer Systems (ICCS) together with the Division of Circular Economy & Tracing of the I-SENSE Group. For this year, the event was organised in collaboration with CEPS. The series brought together stakeholders from diverse sectors who exchanged insights, addressed challenges, and highlighted the critical role of Digital Product Passports (DPPs) in advancing circular economy practices and driving progress towards climate neutrality.
In addition to fruitful discussions, the event featured a series of interactive workshops. In particular, three workshops took place, exploring key governance challenges surrounding DPP data interoperability challenges and DPP related innovation which were built around a common scenario, to facilitate interactions.
This year’s edition spotlighted the W2W Project, an initiative dedicated to the transformative valorisation of wood waste. W2W promotes a circular economy by extending the lifecycle of wood-based materials and diverting them from landfills and incineration facilities.
View here the full agenda of the event.
Key takeaways from this event
1. DPP as a core of product information. As Omnibus IV, the Ecodesign Directive and the Single Market Strategy take effect, the DPP is becoming the main channel for communicating product information with digital labels, safety information, technical files and lifecycle data integrated.
2. The rise of DPP-like systems globally makes interoperability critical. Several non-EU countries (e.g. Vietnam, China) are developing systems similar to DPPs, although often supporting different goals, then the ones introduced by EU. This creates urgency for interoperability as well as sustainability and circularity reference and international standards.
3. Common data structures as first priority. A first immediate task is to define common data structures and interoperability protocols at EU level, ensuring that DPP information can travel across value chains, regulatory systems and borders.
4. Obligatory DPP adoption should be accompanied by adequate support measures. A clear legal mandate making DPPs obligatory across product groups should be supported by financial incentives to reduce the cost of early adoption and help local authorities build the necessary capacity.
5. Several practical challenges still need to be addressed. Lack of stakeholder readiness, uncertainty concerning the data formats and data access levels, as well as difficulties in collecting data from multiple actors across the product lifecycle should be addressed through clearer guidance and sharing best practices.
6. DPPs can strengthen market surveillance. Measures outlined in the Toy Safety Regulation show that DPPs could be used by authorities to access reliable product data, driving the path towards DPP to be used as a tool for improving conformity checks.
Responsibilities and verification roles need to be clearly defined.
The responsibility for the DPP data might be unclear and/or shared across the value chain.
Policy Recommendation:
Provide accountability map specifying stakeholders owning each data category, actors responsible for keeping it up to date and those in charge for verifying its accuracy.
There is concern, that DPP implementation might create extra burden for companies.
The concern about extra financial burden related to collecting, maintaining, and verifying DPP data was expressed.
Policy Recommendation:
Introduce simplified reporting pathways and SME support tools as well as financial incentives
Update responsibilities related to specific lifecycle events.
Participants agreed, that in most cases, DPP data updates occur after specific lifecycle events like repairs, component changes or certification expiration. Those events trigger data updates.
Policy Recommendation:
Define rules for event-based updates, namely updates triggering events, allowed update period and stakeholders, who will be responsible for keeping the record of the product updated.
Harmonization of standards is essential, as many data fields lack unified, machine-readable formats, creating fragmentation across stakeholders.
Policy Recommendation:
The EU should promote a single harmonized DPP data model across product categories, aligned with ISO standards, ESPR requirements and FAIR principles, and delegated acts. This includes common data structures, controlled vocabularies, and consistent formatting rules to ensure interoperability throughout the value chain.
Verification and certification mechanisms must be strengthened, particularly for product ID, recycled content, and certificates, where reliability and accuracy are recurring issues.
Policy Recommendation:
Introduce an EU-wide digital verification and certification framework covering key attributes (e.g., recycled content, product ID authenticity). This should include accreditation criteria for verifiers, digital signatures, mass-balance verification (ISO 22095), and mandatory certificate validity periods to support trust and enforcement.
Data privacy and policy alignment are critical, especially for datasets like repair records that may involve personal information subject to GDPR constraints.
Policy Recommendation:
Develop GDPR-aligned sectoral guidance for DPP data handling, including rules for pseudonymization, data minimization, and role allocation (controller/processor). Ensure that ESPR data obligations and product-safety requirements are harmonized with privacy protections.
Clear guidelines and structured data models are needed for end-of-life instructions, carbon footprint data, and other dynamic fields, which currently face inconsistencies in format and use.
Policy Recommendation:
Publish EU harmonized guidelines (under ESPR delegated acts) defining standardized calculation methods, reporting formats, machine-readable schemas, and harmonized end-of-life EoL instruction models. These requirements should support automated data exchange and ensure consistency across Member States.
The innovation potential of the novel enabling features of an ESPR-backed DPP seems under-evaluated.
Many envisioned “DPP use cases” do not necessarily require an ESPR-backed DPP. For example, information exchange between manufacturers and customers has long been possible. However, an ESPR-backed DPP introduces game-changing features, such as manufacturer-independent information access across all brands. These capabilities enable new business roles (e.g., third-party repair services, data-driven marketplaces) and create opportunities for manufacturers to differentiate and monetize their offerings.
Policy Recommendation:
Clearly communicate the novel enabling features of an ESPR-backed DPP and the resulting innovation opportunities.
The economic impact of transparency alone remains unclear.
Many envisioned DPP use cases aim to provide transparency and build trust around product sustainability performance indicators. However, it is often unclear whether—and how—manufacturers can monetize improved sustainability.
Policy Recommendation:
Develop clear economic incentives and business cases for manufacturers of more sustainable products.
Policies that enable more radical innovation should be predictable and stable.
Game-changing features of an ESPR-backed DPP (e.g., information requirements, access rights) and related policies (e.g., performance standards, right-to-repair regulations) can and should enable circular innovation and increase its profitability. However, uncertainty and risk associated with policy-dependent innovation remain significant.
Policy Recommendation:
Minimize risks of investing in circular innovation by implementing predictable and stable policy frameworks.
Contributor: Bernhard Bergmair
Project: PACE_DPP – Promoting and Accelerating a Digital Product Passport-based Data-Service Ecosystem
Funding: This Lighthouse Project has been made possible by financial contributions from the Austrian Federal Ministry for Climate Action, Environment, Energy, Mobility, Innovation and Technology (BMK), supported by the Austrian Research Promotion Agency (FFG), as well as from the German Federal Ministry for Economic Affairs and Climate Action (BMWK), supported by the German Research Promotion Agency (DLR-PT).
https://www.linkedin.com/company/dpp-austria
Affiliation of Bernhard Bergmair
Silicon Austria Labs GmbH
Research Center for Electronics and Software Based Systems
https://www.silicon-austria-labs.com/
https://www.linkedin.com/company/silicon-austria-labs
DPP Event Recording – Part A
DPP Event Recording – Part B
Stay tuned for future events in the Digital Product Passport & Tracing series!