Digital Product Passports for Circular Supply Chains
and other textile brands, agreeing on 125 textile-specific data points [ 6 ]. Each of these initiatives is technically credible. None alone covers the full DPP universe a single product encounters as it crosses sectors and borders. Whether they interoperate at the level of identifiers, semantic schemas, governance, and trust will determine whether the European DPP becomes a genuine data infrastructure or a fragmentation of compliance silos. Since May 2026 this question has acquired a partial European answer: CEN and CENELEC published the first six horizontal DPP European Standards under JTC 24, establishing a common technical baseline onto which the sector initiatives above must now map [ 19 ].
1.3 STATEMENT OF CONTRIBUTION
Two further infrastructure elements represent gaps this paper flags. First, ESPR Article 13 mandates an EU-wide DPP Registry, scheduled to launch in July 2026, functioning as a central index returning the location of each product’ s DPP data rather than hosting it centrally [ 25 ]. This is directly relevant to the federated architecture in Section 5, which must interoperate with the Registry rather than treat it as a centralised bottleneck. Second, the ESPR Working Plan 2025 – 2030( COM( 2025) 187, adopted April 2025) governs all delegated act sequencing and confirms textiles and iron and steel as the next priority categories [ 26 ]. Implementers scoping DPP roadmaps should read the Working Plan alongside the sector pilots described in Section 2.
This paper distils observations from two parallel DPP pilot programs, one in industrial batteries, one in textiles operated by the authors’ organisations. Rather than restate the technical specification, it asks an architectural question: what does it take to make a DPP useful across the entire supply chain, not only at the point of declaration?
We make three contributions. First, we document the implementation barriers our pilot teams encountered when stitching together CIRPASS-style requirements, Catena-X / GBA data models, and the existing PLM, ERP, and MES estate of manufacturers, suppliers, and recyclers. Second, we position these barriers in relation to mature, public frameworks: UN / CEFACT Recommendation 49 and the United Nations Transparency Protocol( UNTP) [ 7 ], the Industry IoT Consortium( IIC) Material Circularity Framework Principles for Discrete Manufacturing( June 2024) [ 8 ], and the W3C Decentralized Identifiers( DIDs) and Verifiable Credentials( VCs) specifications [ 9 ]. Third, we propose an architectural and governance pattern“ five principles plus a reference stack” that prioritizes open standards, vendor neutrality, and SME inclusion.
The intended audience is operational leadership and supply-chain architects now scoping DPP roadmaps under tight regulatory deadlines.
2 BATTERY AND TEXTILE DPP USE CASES
2.1 BATTERY PILOT SNAPSHOT
The battery programme followed a Tier-1 cell-and-module supplier serving a European EV and industrial-battery OEM, across a fifteen-month window. Scope covered three module families and the four regulated active materials( specifically cobalt, nickel, lithium, and natural graphite) traced through three supplier tiers, from cell assembly( T1) to active-material processors( T2) to
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