What has to be ready before your category's date

The digital product passport (DPP) becomes mandatory category by category from 2027. Whichever category you are in, the preparation window is the transitional period between the delegated act for your product group and the day the obligation binds, and that period is between 18 and 36 months.

That sounds generous until you look at what has to happen inside it. Most of the work is not building anything. It is finding out what your suppliers can prove, and that runs on their calendar rather than yours.

Ten steps, in the order they have to happen.

Step 1. Map your product categories and their estimated date

You cannot plan the work until you know which of your products fall under the regulation first, and roughly when. Two dates are already settled: the EU DPP Registry went live on 20 July 2026, and the battery passport is mandatory from 18 February 2027 under the Battery Regulation (EU) 2023/1542, which is a separate track from ESPR. Everything else runs on the 2025-2030 Working Plan and is indicative: iron and steel first, then textiles and apparel, tyres and aluminium, then furniture and mattresses, with electronics later and construction products on their own CPR track.

A delegated act adoption date is not a compliance date. For any category whose act is not yet adopted, the honest planning assumption is "in phases from 2027". The full breakdown is in our EU DPP regulation timeline.

*Ask yourself: which of our product lines is most likely to be in the first wave, and what is its realistic date?*

Step 2. Name the DPP owner

A passport with no owner is data nobody keeps current. The DPP sits between sustainability, supply chain, IT and legal, which is exactly why it stalls: four functions each assume it belongs to one of the others. One named person needs authority over supplier data, not a committee that meets quarterly.

*Ask yourself: if an auditor asked for our DPP data today, whose name would the company give?*

Step 3. Inventory what you have against what is missing

Most of the gap is invisible until it is written down. Take the field groups your category will require and mark each one three ways: we can prove this with a document today, we hold it but cannot evidence it, we do not have it at all. The third column is your project plan.

*Ask yourself: of the fields a passport requires, what share can we already prove with a document?*

Step 4. Map critical suppliers and what they can document

A large part of passport data lives upstream, with companies you influence but do not control. This is the longest pole in the project, every time. A supplier who has never been asked for recycled content evidence will not produce it in a fortnight, and some will not be able to produce it at all, which is a sourcing decision rather than a data one.

*Ask yourself: which suppliers would block our passport because they cannot yet provide verified data?*

Step 5. Verify material traceability

Origin, share of recycled content, substances of concern. These are the fields auditors and customs check first, and the ones companies most often estimate rather than prove. A supplier declaration is a starting point, not evidence.

*Ask yourself: can we trace our main material back to its origin with evidence, not a claim?*

Step 6. Choose the data carrier, and where the record lives

The carrier has to survive the product's life and bind to one item, not one product line. A label that falls off is not a passport, and a code anyone can duplicate does not prove anything about the item it is stuck to. The technical form of that link is covered by IEC 61406.

*Ask yourself: will our carrier still be readable, and still prove authenticity, years from now?*

Step 7. Align data on sustainability, repairability and end of life

The regulation exists to drive circularity, so these fields are not optional extras. They are graded, and they increasingly appear in tender scoring, which means they affect revenue before they affect compliance.

*Ask yourself: can a buyer see how to repair, reuse or recycle our product straight from its passport?*

Step 8. Set an update process, because the passport is alive

A record frozen at launch is wrong within a season. Suppliers change, formulations change, recall status changes. The process that keeps the passport current is the actual deliverable. Everything before this step produces a snapshot; this step is what makes it a passport.

*Ask yourself: when a supplier or a material changes, how fast does our passport reflect it?*

Step 9. Prepare provability for audits and tenders

Compliance is not holding the data. It is being able to show the right slice to the right party on demand, without exposing what they should not see. An auditor, a customs officer, a recycler and a consumer are entitled to different views of the same record.

*Ask yourself: could we hand an auditor a verifiable view in minutes rather than weeks?*

Step 10. Set milestones with 12 to 18 months of margin

Mapping suppliers and cleaning data takes twelve to eighteen months done properly. Working backward from the date is the only plan that survives contact with a real supply chain.

*Ask yourself: counting back from our first date, should the data work already have started?*

The mistake that costs the most

Treating the passport as a one-off IT project instead of a continuous data process.

A QR code generated once and bolted on the week before an audit is the most expensive form of compliance. It looks finished, and then it fails the first time the data is checked or the product changes. The companies that get this right treat the passport as a process with an owner, a data pipeline and a way to prove authenticity, not a file they ship and forget.

The technical layer, once the data work is under way

Steps 1 to 5 are organisational and they gate everything else. Once they are moving, the implementation questions become concrete:

• define the passport schema for your category: materials, certifications, sustainability fields
• assign model codes to your product lines
• capture the operator identifiers, GLN and EORI, that identify the company behind
• the passport
• choose the identification link, following IEC 61406
• plan multilingual metadata for the markets you sell into
• pick a delivery API so authorities and partners can reach the record

None of these are the hard part. They are a few weeks of work against the twelve to eighteen months the supplier data takes, which is why the order in this page matters more than the list.

Where Junction fits

Junction automates steps 3 to 9. It collects and enriches product and supplier data, generates the passport your category requires, keeps it current as the product changes, and binds one code per item that works as both a passport and a certificate of authenticity.

Have you already mapped your DPP readiness?

Download the full checklist, with the supplier questionnaire and a milestone template you can work backward from. Free, no email required.

Sources

• Regulation (EU) 2024/1781 (Ecodesign for Sustainable Products Regulation).
• ESPR Working Plan 2025-2030, COM(2025) 187, adopted 16 April 2025. Per-category dates are
• indicative; each delegated act adds an 18 to 36 month transitional period.
• Regulation (EU) 2023/1542 (Battery Regulation), battery passport mandatory 18 February 2027.