Introduction

The EU’s Digital Product Passport has moved from policy to practice. The central registry opened on July 20, 2026, and the first product category, large batteries, has a hard deadline of February 18, 2027. For most companies, the real work is not choosing a software vendor. It is figuring out how much of the underlying data they already have, how much they need to collect from suppliers, and which tool actually helps with that rather than assuming the hard part is already done.

Key Takeaways

• Most of the technical rulebook behind the passport already has legal backing. A smaller part, covering security and authentication, is still catching up.
• The hardest part of compliance is usually not software. It is collecting accurate material, origin, and carbon data from suppliers who may not track it digitally themselves.
• Carbon footprint and emissions data a company already tracks for other reporting should not need to be recalculated for the passport.
• Good software should help with data collection itself, not just passport creation and registry submission.
• A tool built narrowly around one product category’s requirements may need significant rework as new categories get their own rules.

What Does the EU Actually Require From You?

Under the Ecodesign for Sustainable Products Regulation, most physical products sold in the EU will eventually need a Digital Product Passport: a structured digital record of what a product is made of, where it came from, and what happens to it at end of life. The regulation itself does not say what software to use. It leaves the technical detail, how the passport is identified, carried on the product, and exchanged between systems, to a separate set of eight European standards.

As of mid-2026, six of those eight standards already carry official legal backing, meaning a passport built to them is treated as meeting the corresponding legal requirements. The remaining two, covering who can access passport data and how it is verified as genuine, are close to the same status but are not there yet. In practice, this means the basic plumbing of the passport, how a product is identified and how its data moves between systems, is settled. The security and authentication side is still catching up.

The Real Challenge: Getting the Data, Not Just Building the Passport

Most of the difficulty in Digital Product Passport compliance has little to do with software and everything to do with data collection. A passport needs material composition, country of origin, carbon footprint figures, and recyclability information, much of which sits with suppliers rather than the company selling the finished product. For a multi-tier supply chain, that means going back to component suppliers, sometimes several layers deep, many of whom track this information on paper, in spreadsheets, or not at all.

This is the part of the process that tends to stretch out over months, not the passport creation itself. A software tool that only handles the identifier, the QR code, and the registry submission is solving the easier half of the problem. The harder half is getting reliable data from a supply chain that was never built to produce it.

What Actually Solves This?

The answer to the data problem above has two parts: stop recollecting data you already have, and get real help with the data you do not.

On the first part, check what your company already tracks for other reasons before treating this as a project that starts from zero. If you calculate product carbon footprint or emissions data for a CBAM declaration, a CSRD disclosure, or a customer request, that figure should not need to be recalculated separately for the passport. The same applies to material composition data collected for other environmental disclosures. Software that treats the passport as disconnected from data you already maintain is asking you to redo finished work, and it creates a real risk: the same carbon figure can come out slightly different in two systems, which is exactly the kind of mismatch an auditor or a customer might catch.

On the second part, for the supplier-level data your company genuinely does not have yet, useful software should actively support the outreach and follow-up involved in getting it, not just provide a form to fill in once the numbers have already arrived from somewhere else. Beyond these two, the passport itself still needs the basics: a compliant product identifier, a data carrier such as a QR code that works with an ordinary smartphone, and registration with the EU system, which currently supports both manual and automated submission and issues a proof of registration. A tool also has to keep that passport accessible and current for the entire life of the product, which can run a decade or more, so it is worth asking how a vendor handles that ongoing responsibility, not only how they handle the first passport created.

Keeping Up as More Product Categories Get Their Own Rules

Batteries are first, but they will not be the only category with rules. Textiles, furniture, and metals are all expected to follow over the next few years, each with their own required data fields. Software built narrowly around today’s early requirements can need significant rework once those rules land, which is worth asking about before signing a contract. A vendor that can already register products with the EU system today, and can point to how their platform has adapted so far, is a reasonable sign they can keep up with what comes next.

A Practical Checklist for Evaluating DPP Software in 2026

• Does the tool help with supplier data collection, or does it assume the data is already clean and ready to import?
• If you already track carbon footprint, emissions, or material composition data for other reporting, does the tool build on that, or ask for it again?
• Can it generate a compliant identifier and a data carrier that works with an ordinary phone, no special app required?
• Can it register a product with the EU system today, and produce a valid proof of registration?
• Who is responsible for keeping the passport accessible over the product’s full lifetime, and how does the tool support that?
• Is the underlying data model built around one product category, or flexible enough to take on new categories as their rules arrive?
• What has the vendor’s track record been so far in adapting to new requirements as this framework has developed?

Conclusion

Data collection, not software selection, is the real bottleneck most companies face on the way to Digital Product Passport compliance. Companies that already track product carbon footprint or life cycle data for other reasons have a genuine head start, since that work should not need to be repeated. The most useful question to ask before choosing any tool is whether it actually helps with the hard part, supplier data collection and reusing data you already have, or whether it only covers the parts of the job that were already straightforward.

ASUENE’s platform now includes Digital Product Passport functionality built directly on its existing life cycle assessment capability, so companies already using it for carbon and product data do not need to start a separate system to meet this requirement.

Why Work with ASUENE Inc.?

ASUENE is a key player in carbon accounting, offering a comprehensive platform that measures, reduces, and reports emissions, including Scope 1-3. ASUENE serves over 56,000 clients worldwide, providing an all-in-one solution that integrates GHG accounting, ESG supply chain management, a Carbon Credit exchange platform, and third-party verification.

ASUENE supports companies in achieving net-zero goals through advanced technology, consulting services, and an extensive network.