DPP: the European registry is live, and the battery deadline reveals the real product data challenge

What the opening of the registry actually changes

The European registry is not a giant database centralizing information on every product sold in the Union. Its function is narrower: it allows a verified economic operator to record proof that a passport exists for a given product, at a level defined by the applicable regulation (model, batch or item depending on the case). The detailed data stays managed by the company responsible for the product, while the registry references the unique identifiers and the associated metadata.

Six technical standards have also already been published, covering unique identifiers, data carriers, APIs and system interoperability. In other words, the technical infrastructure of the DPP is no longer a point of uncertainty: for most companies, the gap left to close is no longer regulatory, it is organizational, and it concerns the data itself.

This decentralized architecture has a direct consequence for you: the point is not to send a file to Brussels once and for all, but to maintain reliable, accessible and interoperable product data over time, ready to be exposed whenever the regulation requires it.

DPP 2027: batteries, the first full-scale test

Companies dealing with batteries are the first that will have to meet this requirement in practice, as early as February 2027. This case is revealing, because it immediately exposes the real complexity of the data required: product identity, chemical composition, carbon footprint, recycled content, performance, state of health, dismantling and recycling instructions. Not all of this information is intended for the same audiences either: some is accessible to any consumer, some is reserved for enforcement authorities or for parties demonstrating a legitimate interest, such as recyclers. And part of this information does not come from the company placing the product on the market, but from its suppliers and subcontractors.

What the battery passport reveals foreshadows a question other sectors will have to ask themselves as new categories enter the ESPR timetable (textiles, electronics, furniture, aluminium, tyres and mattresses in particular):

The real obstacle is not the QR code

A digital identifier is only a way in. It does not know whether a piece of data is correct, whether a supplier certification has just expired, or which of two contradictory versions of the same information should prevail. Producing a reliable passport assumes the data has been through a complete cycle:

This is where the subject meets PIM and MDM concerns head on. In most companies, part of the necessary information already exists, but rarely in the same place: commercial characteristics in the PIM, bills of materials and components in the PLM, certificates in the DAM, composition data at the supplier, some additional information in a spreadsheet. So the problem is not always starting from scratch. It is knowing which application holds the reference data, who is responsible for it, and how to link it to the products that depend on it.

5 questions to assess the maturity of your product data

If several answers remain unclear, the first task of DPP 2027 is not generating the passport itself, but structuring the data that will feed it.

Moving beyond the isolated product record

Take a simple example: one material goes into the composition of 2,000 product items. Copying its characteristics into each of those 2,000 records creates duplication that becomes unmanageable as soon as the certificate changes, the supplier evolves or a characteristic has to be corrected.

A multi-domain approach instead treats that material as a data object in its own right, linked to the products concerned and to its supplier. The associated certification can itself be managed as a separate object, linked to the material.

PIM and MDM: orchestrating the data, not duplicating it

A PIM or MDM platform does not, on its own, make a company ESPR-compliant. Its role is to create an orchestration layer between the systems that each hold part of the information: the ERP for management, the PLM for design, the DAM for documents and assets, the suppliers for the data they are responsible for. The goal is not to copy everything into one place, but to know which data comes from where, how it links to the rest, and how it can be exposed reliably.

Where to start

Rather than launching a full DPP program straight away, the most useful exercise is to take a product that is representative of your catalog and try to reconstruct its history: which materials it is made of, which suppliers are involved, which certifications are attached to it, where the corresponding documents sit, who holds each piece of information, and if one of them changes tomorrow, whether you immediately know which other items will be affected.

This exercise quickly reveals the real maturity of your organization against the DPP. If it currently takes several pieces of software, some Excel files and a call to the supplier, the priority is not yet the identifier to be placed on the product.