As the European Union (EU) prepares to roll out its Digital Product Passport (DPP), manufacturers across industry are facing both a regulatory challenge and a transformative opportunity. While much of the detail around how DPP will work in practice remains unknown, its potential reaches far beyond a sustainability initiative and will unlock value across multiple business areas. Here, Kaja Flottorp, sustainability specialist at metal cutting and manufacturing solutions provider Sandvik Coromant, explores what we know about DPP so far.

Introduced under the Ecodesign for Sustainable Products Regulation (ESPR), the DPP is expected to take the form of a structured, digital record that provides lifecycle data for each product in a standardized format. Proposed data points include material composition, carbon footprint, repairability and end-of-life instructions. However, the exact scope, format and implementation requirements are still evolving.

Some organizations have used their own form of DPP for some time. One example can be found within the wider Sandvik Group. Development of Sandvik’s battery passport began in 2023 within its mining business area, where an initial minimum viable product was created. Since then, the initiative has evolved in stages – from defining the underlying system architecture to developing a scalable solution intended to support all Sandvik divisions.

Beyond batteries, this development is also laying the foundation for broader DPP deployment across the company. By enabling end-to-end material traceability, the solution supports responsible sourcing of critical raw materials and improves the accuracy of carbon footprint reporting. It also strengthens opportunities for second-life applications and recycling by making key information such as battery health, composition and handling requirements more accessible throughout the product lifecycle. For Sandvik, the initiative is not only a compliance measure, but also a driver of greater transparency and more circular business models.

Looking further afield, DPPs are expected to reshape how products are placed, sold and traded across the EU market. While many aspects of the framework are still being defined, the direction of travel is becoming increasingly clear. As the EU continues to refine the regulatory details, businesses can already begin preparing by investing in traceability, data infrastructure and lifecycle transparency.

Progress so far

While indicative timelines have begun to emerge, there is still no full confirmed or finalized schedule for how DPP requirements will be implemented. Under the EU’s Ecodesign for Sustainable Products Regulation, iron and steel as intermediate products have been identified as priority categories, meaning they are likely to be among the first to see more detailed rules take shape.

Current guidance suggests that delegated acts for iron and steel could be introduced from 2026, with compliance potentially following from 2027. In proposal documentation, the EU has outlined that likely data categories for steel could include product and producer identification, material composition and technical data, environmental and circularity data as well as details of any substance of concern. However, much of the current direction remains based on preparatory studies and draft proposals that are still subject to further refinement.

What becoming clear, however, is the broader trajectory. Iron and steel are being prioritized due to their environmental impact and central role in industry supply chains, with early requirements expected to focus on energy efficiency and material transparency. Given this evolving landscape, manufacturers should avoid anchoring their plans to fixed dates at this current stage. Instead, understand what data is already available, how it can be structured and where gaps remain.

At the crossroads

At its core, DPP presents as a sustainability initiative. While it’s true that it will support more efficient remanufacturing, facilitate second-life applications and improve recycling outcomes, DPP shouldn’t only be seen as the responsibility of sustainability managers. In reality, it will sit at the crossroads of multiple business functions.

Compliance teams will need to understand the types of data required, and with that comes questions of what can and should be shared publicly. IT teams will need to assess how existing systems can support the structuring, storage and exchange of data. Beyond this, operations and products teams will play a critical role in ensuring that accurate, consistent data is captured at the source, while procurement functions may need to work more closely with suppliers to improve upstream transparency.

Taken together, DPP is less a single initiative and more a shift in how product data is managed, governed and used across an organization. While the exact requirements are still evolving, businesses that begin aligning these functions early will be better positioned to respond as greater clarity emerges.

To help manufacturers prepare for DPP requirements, Sandvik Coromant is participating in the Digital Metal Value Chain collaboration coordinated by the industrial research institute Swerim. Together with partners across the steel value chain, the initiative explores how product data such as material composition, environmental performance and chain of custody can be structured, shared and applied in practice.

As an early mover, the focus is not on waiting for final regulation, but on testing real-world use cases, identifying data gaps and transforming existing product data into business value through practical pilot projects.

The EU’s DPP initiative has a far-reaching scope that will reshape how manufacturers design, document and deliver products. While industry awaits the finer details, it’s sensible to get a head start in understanding what enhanced traceability means for supply chains and how it can be embedded into everyday operations. By building the foundations now, manufacturers can move from reactive compliance to proactive value creation.