Digital Product Passports Become the Backbone of EU Product Compliance

December did not deliver new Digital Product Passport (DPP) laws, sector-specific delegated acts or revised timelines.

Instead, it delivered something arguably more important: confirmation of how central DPPs will be to the EU’s entire product compliance system.

If earlier months were about momentum and enforcement signals, December was about structure, quietly positioning the Digital Product Passport as the single interface through which multiple regulatory obligations will flow.

For manufacturers and exporters, this marks a clear shift from planning to execution.

What's New

The most significant development in December came through the European Commission’s environmental simplification work.

While not positioned as a standalone “DPP announcement”, the message was clear: the EU intends to remove parallel reporting systems and consolidate product-level compliance data through Digital Product Passports.

This includes plans to phase out the SCIP database for substances of concern, with hazardous-substance disclosures instead accessed via DPPs.

At the same time, Extended Producer Responsibility (EPR) obligations are being simplified, particularly for products sold cross-border with reduced authorised-representative requirements and streamlined reporting.

Crucially, these simplifications are designed to work through DPP-linked data, not alongside it.

In practical terms, this confirms that DPPs are no longer an additional obligation.

They are becoming the container for multiple compliance regimes.

Who Governs DPPs, And How Enforcement Will Work

As Digital Product Passports move closer to enforcement, a common question is emerging: who governs DPPs, and who checks that they are compliant?

At a framework level, DPPs are governed centrally through EU legislation under the Ecodesign for Sustainable Products Regulation (ESPR). 

In practice, governance operates through binding law, with product-specific delegated acts defining what data must be included in a Digital Product Passport, and implementing acts setting out how DPPs must function in practice.

The overall system sits with the European Commission, which:

• Sets the legal basis under the ESPR

• Defines what data must be included through sector-specific delegated acts

• Aligns DPPs with related regulations covering batteries, chemicals, waste and construction products

Enforcement, however, follows the EU’s established model.

Rather than a single EU-level authority, national market surveillance bodies and customs authorities will enforce compliance. Digital Product Passports will be checked both at EU borders and within the internal market, using DPPs as the primary verification layer for product compliance.

In practical terms, this allows regulators to:

• Access product data digitally

• Verify compliance without manual documentation requests

• Scale enforcement across more products, more frequently

For manufacturers and exporters, this has clear implications:

• Responsibility sits with the economic operator placing the product on the EU market

• An incomplete or inaccessible DPP is itself a compliance issue

• Enforcement will scale digitally, not selectively

December’s shift toward DPPs as a single compliance interface explains why this question is surfacing now.

How TAZAAR Can Help

As Digital Product Passports move from concept to compliance infrastructure, the challenge for manufacturers is no longer understanding the regulation, it is operationalising product data at scale.

TAZAAR supports organisations by:

• Mapping product and supply-chain data to future DPP requirements

• Helping structure, validate and manage product-level data

• Supporting readiness across ERP, PLM and compliance systems

• Enabling scalable DPP deployment without unnecessary duplication

This approach ensures businesses are not reacting at the point of enforcement, but building resilient, future-proof product data foundations.

DPPs are no longer positioned as a sustainability add-on.

They are becoming the digital backbone of EU product compliance, consolidating reporting, enabling enforcement and standardising access to product data.

With 2026 now firmly established as the execution year, December marked the moment when preparation stopped being optional.