Regulatory Digital Product Passports as a Catalyst for U. S. Supply Chain Visibility
survey results. The assessment also examined organizational adoption patterns, interoperability constraints, and ecosystem governance considerations.
DATA SOURCES
The assessment focused on whether DPP ecosystems could increase the availability of structured provenance data, product composition data, verifiable claims, and machine-readable lifecycleevent data. Particular attention was given to ESPR, UNTP, SPDX 3.1, and associated digital-thread and BOM interoperability ecosystems.
SCOPE OF ASSESSMENT
This paper draws on findings from MITRE’ s March 2026“ Regulatory Impacts to U. S. Supply Chain Data” seedling assessment, which examined whether emerging Digital Product Passport( DPP) regimes could materially change the availability and utility of structured supply chain data within and through the United States. The assessment combined policy analysis, standards analysis, industry ecosystem review, and a limited exploratory survey to evaluate both technical feasibility and organizational adoption dynamics.
3 ASSESSMENT FINDINGS
LIKELIHOOD OF DPP DATA EXISTING AT SCALE
Our assessment concludes that ESPR— reinforced by EU market incentives— will very likely drive industries to capture standardized, structured DPP data on products and provenance. The seedling characterizes ESPR as balancing " stick " incentives( risk of EU market exclusion and penalties) with " carrot " incentives( operational efficiency, ethical sourcing management, improved risk management, and improved supply chain security confidence). From an adoption standpoint, this balance aligns with broader observations that external pressure and market access constraints can overcome switching costs and path dependency that otherwise slow migration to open standards, and that standardization efforts often fail when incentives and critical-mass dynamics do not align [ 8 ], [ 9 ].
Similar to the EU Cyber Resilience Act and GDPR before it, ESPR is already catalyzing ecosystem activity well before full delegated-act implementation, including consulting services, enterprise pilot efforts, traceability tooling, and industry guidance development. For large manufacturers, DPP implementation is unlikely to remain confined to sustainability-reporting functions; product lifecycle management, ERP, procurement, logistics, supplier management, and compliance workflows may all require integration to support lifecycle-level provenance and claims management.
At the same time, organizations may pursue lowest-common-denominator compliance behaviors that satisfy formal disclosure requirements while minimizing operational disruption. Such behaviors could include shallow supplier attestations, selective disclosure, over-reliance on estimated sustainability metrics, or minimal provenance depth beyond immediate suppliers.
EDM Association – Journal of Innovation 31