SINE Strategy Wiki

Digital Product Passport (DPP)

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A compilation of data attributes describing a product, its components and materials: sustainability indicators, composition, use, repair, reuse and recycling info (e.g. for batteries, textiles, buildings). Positioned as the key regulatory tool for monitoring product- and company-level sustainability requirements (Scope 3 externalities included).

Driven by EU regulation: Ecodesign for Sustainable Products Regulation (ESPR), the Battery Regulation, and the Corporate Sustainability Reporting Directive (CSRD) at company level. ESPR itself only gives vague technical detail; secondary legislation (delegated/implementing acts) is expected to fill this in.

The problem: fragmentation

At least 76 competing EU DPP projects exist (Jansen et al. 2022, Wuppertal Paper 198), plus comparable efforts abroad (e.g. Tesla). No agreement exists on data format or how product data should be collected/curated. Without a harmonized framework, this fragments into non-interoperable data silos, causing:

  • Impeded data aggregation — can’t combine DPP data across product categories/industries (e.g. to compute total footprint) if formats differ.
  • Lock-in effects — switching a DPP format is costly (re-collect data, re-verify via external auditors).
  • Exploitation / data misuse — DPP organizations can become gatekeepers, charging high fees and imposing unfavorable data-use terms that threaten producers’ data sovereignty.
  • Market failure — powerful actors could build proprietary DPP ecosystems to exploit monopoly position and block competitors.
  • Impeded technological progress — rigid data requirements raise the cost of developing new product groups.

Goal: 4 use cases a harmonized landscape must enable

  1. Automated and reliable data integration
  2. Comparison and aggregation of different DPPs
  3. Easy set-up of new DPP ecosystems
  4. Easy switching between DPP ecosystems

Proposed governing framework

SINE’s Data Commons framework, applied via ~17 key questions a DPP ecosystem should answer (identity, sovereignty, onboarding, portability, data use, fraud, power balance, etc. — full list on the Data Commons page).

Carbon accounting use case

Scope 3 emissions reporting is moving to center stage of regulatory/ stakeholder demands. Current Life Cycle Assessment (LCA) practice is retrospective (a company looks back into its supply chain), which is costly to make end-to-end. The alternative — upstream data aggregation, where each actor adds its own Scope 1+2 emissions to received materials/components — lowers transaction costs and improves accuracy. This is the approach taken by PACT, the Global Battery Alliance (GBA), and Catena-X. For it to work, interoperable exchange systems compliant with Data Commons values are needed. Sensitive process-specific activity data should only be reported at an aggregated per-unit level, or via advanced (e.g. homomorphic) encryption.

Earlier framing: three value levels (2022 whitepaper)

Before the fragmentation problem above (2023 paper), the 2022 Data Commons whitepaper framed DPP value more simply, in three levels:

  1. Reporting/steering — reliable info on origin/composition/content; e.g. plastics & packaging producers optimizing Extended Producer Responsibility (EPR) reporting and CSRD compliance.
  2. Process optimization — managing material flows across manufacturing, use, and end-of-life; e.g. consumer electronics repair/remanufacturing and improved end-of-life sortation.
  3. New business models — circular or performance-based models; e.g. a battery passport enabling full recollection/second-life use and “as-a-Service” pay-per-use models via smart charging data.

It also names three system challenges to unlocking this value — aligning incentives to share data (reciprocity), improving data security/anonymity/ access (security), and strengthening interoperability/standards (openness) — the same three Data Commons values applied to DPPs specifically, a year before the 2023 paper’s 17-question framework.

Regulatory anchor cited: the EU Battery Regulation makes the Battery Passport the first DPP mandated for all large batteries in the EU, starting 2026 — alongside the Ecodesign Directive’s broader push for more durable, reusable, repairable, and recyclable products.

⟨Note: these appeared only as brief mentions in this one source when this page was first written — WBCSD, GBA, and Catena-X have since been profiled more fully on their own pages (linked above); Battery Pass and CIRPASS remain landscape pointers only.⟩

A parallel rule-making track: Hitachi / AIST

⟨2026-10-16⟩ The DPP is the EU’s instrument for attaching verified product data to the object. Japan is running a parallel, differently-shaped track: the Hitachi-AIST CECRL is standardizing Circular Value-added Productivity (CVP) toward “internationally accepted rules and standards originating from Japan” (Hitachi Sustainability Report 2026, p. 36).

⟨Corrected 2026-10-16, same day, after the CE Association white paper supplied CVP’s defining equations: the two do not share a substrate and barely meet. A DPP is a record about an object; CVP is a ratio over financial-statement items (sales, intermediate-goods costs, COGS, SG&A), and its authors state explicitly that it is “intended to be used at the level of businesses to national governments”, with “a different indicator may be better for product promotion”. The earlier claim here — that CVP’s numerator is the material-composition and prior-use data a DPP carries — was inferred from a one-paragraph summary and is wrong. Retained as a correction rather than deleted, because the mistake is the instructive part: a metric’s name does not tell you its inputs.⟩

⟨Inference: one narrow contact point survives. CVP requires a CE ratio — a segmentation of which revenues and costs are circular — which the study group leaves “up to the companies”. Evidence that a given product line is genuinely circular is the kind of claim a product passport is built to support. That is a possible bridge, not a shared substrate, and the wiki should not assert more than that until something is sourced for it.⟩

The division of labour, stated by the Japanese side ⟨2026-10-16⟩

The correction above holds for CVP and not for the rest of the proposal. At the lab’s Third Open Forum (July 2026), Osamu Hoshino presented a mapping of global rule-making arenas and concluded:

“Europe is taking the lead in areas such as information disclosure through DPPs and the development of data spaces on the upstream sector of the CE loop … At the same time, we identified areas in which Japan could make meaningful contributions to international standardization, including data integration on the downstream sector and the Common Data Dictionary (CDD), an online metadata registry for standardized classifications and formalized product descriptions.”

Keynote speaker Takashi Nakamura, chair of the CE Association and head of Japan’s ISO/TC 323 mirror committee, goes further: “value increasingly shifts from physical products to information. Material platforms such as digital product passports (DPPs) are expected to become promising new business opportunities” — while naming the unsolved part as information sharing “not only across forward supply chains … but also with reverse supply chains”.

And from Hitachi’s commercial side, Hiroko Shinkai (Green DX): the DPP and Battery Passport “provide useful points of reference. However, what matters is not the sheer number of data fields, but whether the information required by the next player in the value chain can be transmitted seamlessly and without interruption.”

⟨Inference: so the DPP is not ignored in Japan and not contested — it is treated as the upstream instrument, with the proposed Japanese contributions sitting downstream of it (reverse-chain integration) and beneath it (a property dictionary both sides reference). The wiki’s contact-point inference above was too narrow: the contact is not CVP’s CE ratio, it is residual-value grading, which carries quality and provenance claims about objects — the same substrate after all, one work stream over.⟩

⟨Background: the Common Data Dictionary is IEC’s registry of standardized product classes and properties, built on the IEC 61360 series. A dictionary defines what a property means; it does not carry data and does not make a claim checkable.⟩

The regulation as a bootstrapping instrument ⟨2026-10-27⟩

⟨From OECD (2026).⟩

The OECD reads product-passport regulation — the EU Battery Regulation (EU) 2023/1542 and ESPR (EU) 2024/1781 — not primarily as a disclosure mandate but as the thing that makes multi-party data infrastructure financeable. Its mechanism: regulation raises every potential anchor participant’s private expected return at the same moment, which is exactly the condition under which the bootstrapping problem stops binding. See the bootstrapping problem.

The worked instance is Japan’s ABtC (Automotive Battery Traceability Consortium, February 2024): 14 Japanese automakers plus the Battery Association for Supply Chain and JAPIA, federated storage with blockchain verification, funded by member fees plus transaction fees, accredited by IPA as a “public interest digital platform operator”, built on ODS-RAM. It exists because Japanese battery suppliers must produce carbon-footprint declarations to retain EU market access. The report’s phrase for this is blunt: EU product regulation “transforms regulatory alignment from a European policy concern into a global market access requirement”.

The IPA–Catena-X proof of concept of March 2025 then exchanged PCF data between the Ouranos Ecosystem and Catena-X for Battery Regulation compliance, across ODS-RAM and EDC implementations — the first demonstrated cross-architecture passport data exchange recorded in this wiki.

Two cautions the report attaches:

  • Usage control does not answer the IP question. It governs how data may be processed, “but does not resolve who owns the value derived from them”. For a passport that accumulates supplier data across a chain, model ownership, derived insights and downstream patent claims remain unallocated. The named case is the US Materials Genome Initiative — over USD 1 billion in federal investment and persistent industry reluctance to contribute proprietary performance data over IP attribution.
  • The regulatory ground may shift. The EU Digital Omnibus (November 2025) would repeal the DGA as a standalone regulation, fold it into the Data Act, make intermediation registration voluntary, and relax the neutrality separation from structural to functional — lowering the barrier for integrated platform operators to run passport infrastructure. See product-level carbon regulation.

Standardisation worth tracking for any passport implementation: CEN/CENELEC EN 18235-1:2026 (published; Parts 2 and 3 in progress), framed explicitly for Data Act Article 33 compliance, and ISO/IEC DIS 26450/26451 (the Eclipse Dataspace and Decentralised Claims Protocols).

The attachment objection ⟨2026-11-06⟩

Source: POLYPROBLEM 06 — Der Circularity Code, pp. 14–15. The sharpest in-source objection to a passport-first strategy in the wiki, made by someone selling the alternative — Jochen Moesslein (Polysecure), and therefore to be read with that interest in view.

Digitalisierung ist ein überschätztes Wort. Die technischen Herausforderungen im Recycling haben wenig mit Digitalisierung zu tun. Wichtig für die Kreislaufwirtschaft sind Erkennungsprozesse, Sortierung und Aufbereitung – und in keinem davon spielt Digitalisierung eine Rolle.

The physical premise: more than half the mass arriving at a sorting plant is shredded fragments, on which object recognition and AI cannot work; what is needed is a physical method that differentiates materials in ten milliseconds — e.g. food-contact from non-food-contact. The allocation claim that follows:

Momentan fließt viel Geld in die Produktpass-Datenbanken. Mindestens genauso wichtig wäre, mehr Geld in die eigentliche Erkennungstechnologie zu stecken. Da ist nämlich der Engpass. Was nützt eine Datenbank, wenn ich einen Eintrag nicht sicher mit der dazugehörenden Datenbank verknüpfen kann?

and its stronger form — that the hype crowds out other investment: “die unrealistischen Hoffnungen, die mit Digitalisierung verknüpft werden, [verzögern] Investitionen in anderen wichtigen Technologiebereichen.”

⟨Inference: the objection is not that product data is worthless but that a DPP is a record without a reliable binding to the physical object at the moment of sorting. Everything on this page concerns the record layer; the identifier layer is assumed. For a bottle with a legible carrier — HolyGrail 2.0’s digital watermark, R-Cycle’s GTIN — the assumption holds. For shredded fragments it fails, and the DPP’s value at end-of-life degrades to whatever can be reconstructed statistically. Moesslein is wrong to frame identification and record as rival claims on the same budget — an identifier that resolves to nothing is as useless as a record nothing resolves to — but right that the binding is the binding constraint downstream, and the EU’s instrument list legislates the record and not the carrier.⟩

Market sizing from the same interview, for scale: 400 Mt of plastic processed per year, about half of it sorted; at €100–200/t for sorting that is “ein Volumen von 20 Milliarden und mehr. Der Markt ist also vorhanden.” Polysecure’s own candidate is its TrackByStars® marker technology as the “Unique Identifier”.

The same report supplies the counter-case in which the carrier problem is being worked: HolyGrail 2.0 digital watermarks, pp. 12–13, with a consortium of Danone, Mondelez, P&G, Unilever, Nestlé, Pepsico, Aldi and Amazon behind AIM and the Alliance to End Plastic Waste — where practical sortability has been demonstrated in trials and the open question is explicitly financial: will recyclers re-equip, and “Wer stemmt die dafür notwendigen Investitionen?”

A third framing from the same source, worth distinguishing from the DPP rather than merging with it: Dominic Santschi (Ampliphi), pp. 30–31, on plastic-waste accounting, where transparency is created “nicht nur zu einem Produkt … sondern für die gesamte Unternehmung” — a company-level unit of account enabling peer benchmarking, needing “eine einheitliche Methodik und Standards … um Vergleichbarkeit zwischen Unternehmen und Glaubwürdigkeit zu gewährleisten”.

Profiling, not harmonisation: what PACT did with identifiers ⟨2026-11-06⟩

This page opens on fragmentation — 76 competing DPP projects, no agreement on data format — and treats harmonisation as the goal. The PACT Technical Specifications v2.2 are a worked example of the other available answer, from the one standard in this wiki that has forty-odd independent implementations.

PACT does not name a canonical product identifier and says why: “What constitutes a suitable product identifier depends on the product, the conventions, contracts, and agreements between the Data Owner and a Data Recipient and is out of the scope of this specification” (§5.1, productIds). What it ships instead is URN namespacing for the schemes that already exist — GTIN, CAS Registry Numbers, IUPAC InChI, plus urn:pathfinder:product:customcode:buyer-assigned:… and …:vendor-assigned:… for bilateral codes — with the mirror pair for company identifiers.

⟨Per Martin Pompéry, 2026-11-06: there are no canonical product IDs. There are only several, and the Tech Specs are in that sense an interoperability profile — a specification whose job is to select from and constrain the standards that exist rather than to crown one. Reading the absence of a single identifier as a gap misreads both the document and the world.⟩

⟨Inference for the DPP debate: the fragmentation diagnosis above stays accurate, but the implied remedy — convergence on one format — is not the only route to the four use cases this page lists, and is probably not the achievable one. Aggregation and comparison need a profile: an agreed envelope, agreed units and vocabularies, and namespaced identifiers that stay plural. Switching between ecosystems needs the same. PACT reached interoperability for carbon without resolving the identifier question at all, and the piece it genuinely could not supply — verifiability — is the piece it declined to profile, not the piece that was fragmented.⟩

⟨And it sharpens the attachment objection above rather than answering it. Profiling settles which symbol systems a record may use; it says nothing about whether a symbol is still readable on a shredded fragment. The identifier layer has two distinct problems — agreement on scheme, and binding to the object — and only the first is a standards problem.⟩

Sources

  • sources/hitachi/2026-07-30-h-aist-ce-lab-third-open-forum.md — Hoshino’s arena mapping, Nakamura’s keynote, Shinkai’s panel remarks ⟨see its page⟩
  • sine-dpp-data-commons-2023 — sources/whitepapers/2023-04-12-sine-whitepaper-final.pdf
  • sine-data-commons-2022 — sources/whitepapers/2022-04-25-data-commons-final.pdf (earlier three-value-levels framing, EU Battery Passport)
  • sources/research/2026-10-27-oecd-data-spaces-co-ordination-viability-public-policy/2026-10-27-oecd-data-spaces-co-ordination-viability-public-policy.md (§2.1, §4.1, §4.3, §4.5, Box 2.1, Box 4.1)
  • sources/standards/2026-10-29-pact-data-exchange-protocol-v2.2.md (§5.1 productIds, §5.19 CompanyId, §5.21 ProductId — the 2026-11-06 section)

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