In-house or supply-chain-based? How your production model determines the success of your Digital Product Passport

A simple question with enormous consequences

Among the first questions to ask when designing a Digital Product Passport (DPP) is one that might seem trivial: do ​​you manufacture the product yourselves, or do you have others manufacture it for you?

In reality, the answer determines almost everything else: where the data is located, how difficult it will be to collect, which contracts need to be renegotiated, which IT systems must communicate with one another, and how much time will be required to get ready. It is no coincidence that the DPP Designer guide includes this as a fundamental question in the "Design Your DPP" process, within the section dedicated to the company.

There are three possible answers:

1. We manufacture in-house
2. We rely on suppliers
3. Both

Let’s look at each one.

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1. In-house manufacturing: the data is (mostly) already in-house

When a product is created within your own facilities, a large portion of the information required for the passport is already recorded in your company’s systems:

• MES (Manufacturing Execution System): batches, dates, production lines, and energy or material consumption;
• ERP: bills of materials (BOMs), item codes, and raw material procurement;
• PLM: design specifications, composition, and assembly/disassembly instructions;
• Quality systems: certifications, testing, and compliance.

Strengths

• Direct control over data quality and traceability.
• Rapid response times: if a field in the DPP needs to change, the correction can be made internally.
• Easier to achieve granularity: linking a passport to a specific batch or individual item is simpler when that batch is generated by your own MES.

A word of caution

"Manufacturing in-house" does not necessarily mean "having all the data." Purchased raw materials and components always originate from somewhere; information regarding the origin of materials, recycled content, substances of concern, or upstream carbon footprint must often be requested from suppliers. Even the most vertically integrated manufacturer has an upstream supply chain that must be engaged.

In this scenario, the real challenge is primarily IT integration: consolidating data scattered across various systems into a single, coherent, and interoperable data model.

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2. Outsourced production: the DPP becomes a supply chain project

When production is entrusted to third parties, workshops, or contract manufacturers, the situation shifts: most of the data originates outside the company. Consider a clothing brand, for example: the exact composition of the fabrics, the country where the garment was assembled, or the treatments applied—these are details held by the workshop, not the brand itself.

The key point: responsibility cannot be delegated

The ESPR (Ecodesign for Sustainable Products Regulation) is clear on one aspect: the entity placing a product on the market must make the passport available, even when the data originates from the supply chain. This means that:

• the economic operator placing the product on the EU market remains responsible for the accuracy of the information, including data provided by suppliers;
• an importer cannot simply "accept" documentation from a non-EU manufacturer; they must verify that the passport meets all requirements before the product is placed on the market;
• in the eyes of regulatory authorities, incorrect data provided by a second- or third-tier supplier remains the responsibility of the party that placed the product on the market.

What is required in practical terms

When working with external suppliers, explicit agreements are necessary across three dimensions:

Dimension	Questions to address in the contract
What data	Which DPP fields must the supplier provide? At what level of detail (model, batch, or individual item)?
In what format?	A shared template, structured files, an API, or a supplier portal? Which coding systems and identifiers should be used?
On what timeline?	By when—relative to shipment—must the data be provided? How frequently should it be updated? What happens if the data is missing?

It is also advisable to include additional clauses: the right to verify and audit, the management of confidentiality (as some data may be competitively sensitive), the obligation to notify of any changes (such as a change in materials, production facilities, or sub-suppliers), and liability in the event of inaccurate data.

Common challenges

• Low digital maturity among suppliers—especially SMEs—who may still manage data using spreadsheets or PDFs;
• Incomplete or delayed data, resulting from manual processes and fragmented systems;
• Limited visibility beyond the first tier of the supply chain;
• Information silos that hinder end-to-end traceability.

For this reason, in a scenario characterized by high levels of outsourcing, the DPP should be approached as a supplier engagement program rather than merely an IT project.

---

A simple question with enormous consequences

Among the first questions to ask when designing a Digital Product Passport (DPP) is one that might seem trivial: do ​​you manufacture the product yourselves, or do you have others manufacture it for you?

In reality, the answer determines almost everything else: where the data is located, how difficult it will be to collect, which contracts need to be renegotiated, which IT systems must communicate with one another, and how much time will be required to get ready. It is no coincidence that the DPP Designer guide includes this as a fundamental question in the "Design Your DPP" process, within the section dedicated to the company.

There are three possible answers:

1. We manufacture in-house
2. We rely on suppliers
3. Both

Let’s look at each one.

---

1. In-house manufacturing: the data is (mostly) already in-house

When a product is created within your own facilities, a large portion of the information required for the passport is already recorded in your company’s systems:

• MES (Manufacturing Execution System): batches, dates, production lines, and energy or material consumption;
• ERP: bills of materials (BOMs), item codes, and raw material procurement;
• PLM: design specifications, composition, and assembly/disassembly instructions;
• Quality systems: certifications, testing, and compliance.

Strengths

• Direct control over data quality and traceability.
• Rapid response times: if a field in the DPP needs to change, the correction can be made internally.
• Easier to achieve granularity: linking a passport to a specific batch or individual item is simpler when that batch is generated by your own MES.

A word of caution

"Manufacturing in-house" does not necessarily mean "having all the data." Purchased raw materials and components always originate from somewhere; information regarding the origin of materials, recycled content, substances of concern, or upstream carbon footprint must often be requested from suppliers. Even the most vertically integrated manufacturer has an upstream supply chain that must be engaged.

In this scenario, the real challenge is primarily IT integration: consolidating data scattered across various systems into a single, coherent, and interoperable data model.

---

2. Outsourced production: the DPP becomes a supply chain project

When production is entrusted to third parties, workshops, or contract manufacturers, the situation shifts: most of the data originates outside the company. Consider a clothing brand, for example: the exact composition of the fabrics, the country where the garment was assembled, or the treatments applied—these are details held by the workshop, not the brand itself.

The key point: responsibility cannot be delegated

The ESPR (Ecodesign for Sustainable Products Regulation) is clear on one aspect: the entity placing a product on the market must make the passport available, even when the data originates from the supply chain. This means that:

• the economic operator placing the product on the EU market remains responsible for the accuracy of the information, including data provided by suppliers;
• an importer cannot simply "accept" documentation from a non-EU manufacturer; they must verify that the passport meets all requirements before the product is placed on the market;
• in the eyes of regulatory authorities, incorrect data provided by a second- or third-tier supplier remains the responsibility of the party that placed the product on the market.

What is required in practical terms

When working with external suppliers, explicit agreements are necessary across three dimensions:

Dimension	Questions to address in the contract
What data	Which DPP fields must the supplier provide? At what level of detail (model, batch, or individual item)?
In what format?	A shared template, structured files, an API, or a supplier portal? Which coding systems and identifiers should be used?
On what timeline?	By when—relative to shipment—must the data be provided? How frequently should it be updated? What happens if the data is missing?

It is also advisable to include additional clauses: the right to verify and audit, the management of confidentiality (as some data may be competitively sensitive), the obligation to notify of any changes (such as a change in materials, production facilities, or sub-suppliers), and liability in the event of inaccurate data.

Common challenges

• Low digital maturity among suppliers—especially SMEs—who may still manage data using spreadsheets or PDFs;
• Incomplete or delayed data, resulting from manual processes and fragmented systems;
• Limited visibility beyond the first tier of the supply chain;
• Information silos that hinder end-to-end traceability.

For this reason, in a scenario characterized by high levels of outsourcing, the DPP should be approached as a supplier engagement program rather than merely an IT project.

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3. Hybrid model: the most common (and complex to manage) scenario

Many companies fall somewhere in the middle: they assemble purchased components in-house, or they manufacture some product lines internally while outsourcing others.