One, ten, or a hundred suppliers? How the number of partners shapes the data strategy for your Digital Product Passport

Why counting your suppliers is the first step

When discussing the Digital Product Passport (DPP), the focus almost always lands on the "what": which fields to fill out, which QR code to print, or which platform to choose. Yet, before any of that, there is a simpler and more critical question: from how many different companies must the data be sourced?

The answer fundamentally changes the nature of the project. With two suppliers, a simple phone call and a shared file might suffice; with two hundred, you need a robust infrastructure. The principle is straightforward: the more suppliers you have, the more essential it becomes to have a standardized format and a structured channel for collecting information. Each additional supplier multiplies the potential for format variations, delays, conflicting versions of the same data, and the workload required for verification.

In this article, we analyze four typical tiers, what they mean in practice, and how to prepare for each one.

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The Regulatory Context: Why Supply Chain Data Is Inevitable

The ESPR: The Big Picture

Regulation (EU) 2024/1781 on Ecodesign for Sustainable Products (ESPR), which entered into force on July 18, 2024, introduced the Digital Product Passport as an electronic tool for collecting and sharing information regarding product composition, environmental impact, repairability, and recyclability. Specific obligations will be rolled out on a product-group-by-product-group basis through dedicated delegated acts.

One often-overlooked point is that, depending on the complexity of the value chain, the passport may be required at the model level, the batch level, or the individual item level. The more granular the level, the more frequent and extensive the data exchange with suppliers will need to be. ### Registry and technical standards: the infrastructure takes shape

In 2026, the system moved from theory to implementation:

• An implementing regulation (EU) 2026/1778 governs the digital passport registry provided for under Article 13 of the ESPR; it stores at least unique identifiers and includes a list of verified DPP service providers. The Commission had set July 2026 as the launch date for the registry.
• On May 27, 2026, CEN and CENELEC—through their joint technical committee, JTC 24—published the first six European standards for the DPP, as requested by the Commission under mandate M/604:
• EN 18216 – Data exchange protocols
• EN 18219 – Unique identifiers
• EN 18220 – Data carriers
• EN 18221 – Data storage and persistence
• EN 18222 – APIs for lifecycle management and searchability
• EN 18223 – System interoperability

For those who need to collect data from multiple suppliers, the standards concerning data exchange (EN 18216) and interoperability (EN 18223) are the ones to watch: they define the "common language" toward which portals and integrations should converge.

The testing ground: the battery passport

The first mandatory DPP does not stem from the ESPR, but rather from the Batteries Regulation (EU) 2023/1542. Starting February 18, 2027, batteries for electric vehicles, light means of transport (LMT), and industrial batteries with a capacity exceeding 2 kWh placed on the EU market must feature a digital battery passport, accessible via a QR code. While supply chain due diligence obligations have been deferred to August 18, 2027, under Regulation (EU) 2025/1561, the deadline for the digital passport remains unchanged.

The case of batteries clearly illustrates the core challenge: data—such as carbon footprint, recycled content, and the origin of raw materials—is not held by the company selling the final product, but rather by suppliers of cells, materials, and raw materials, often several tiers removed. Furthermore, the responsibility for the completeness and accuracy of the passport lies with the economic operator, not the supplier; if data is missing or incorrect, the responsibility is yours.

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The Four Tiers: How Things Change Based on the Number of Suppliers

Tier 0 – No Suppliers: All Data Is Internal

Scenario: The company generates all the data required for the passport (materials, processes, testing, impacts) in-house.

What this means: The challenge is not external data collection, but rather the integration of internal systems. Data is often scattered across ERP systems (bills of materials), PLM software (technical specifications), LCA tools (environmental impacts), and quality management systems.

Operational priorities:

• Map out which system serves as the "source of truth" for each field in the passport.
• Assign an internal owner for each data category.
• Automate data extraction to the DPP (Digital Product Passport) platform to avoid manual steps.

Note: It is rare for a company to be truly 100% autonomous. Material certificates, declarations regarding substances, or packaging data almost always originate from third parties. It is worth verifying this carefully before concluding that your supply chain is not involved.

Tier 1–10 Suppliers: Case-by-Case Management

Typical scenario: A textile company with one fabric supplier and two accessory suppliers.

What this means: With a small number of suppliers, data collection can be handled in a direct, personalized way. You know your points of contact, you can agree on a specific format with each one, and issues can often be resolved with a simple phone call.

Suitable tools:

• Shared spreadsheets with a structure defined by you.
• Alignment meetings at the start of the project.
• A centralized document repository for certificates and declarations.

Risks to manage:

• Dependence on specific individuals: If your contact person at a supplier changes, continuity may be lost. - Divergent formats: Even with just five suppliers, five different files quickly become unmanageable as the number of products grows.
• Updates: The passport must remain valid over time; clear rules are needed regarding who updates what, and when.

Recommendation: Even at this scale, it is advisable to define a minimum data dictionary (field names, units of measurement, formats) from the outset. It requires little effort and makes future growth painless.

Tier 2: 11–50 suppliers – A common model is required

Typical scenario: A manufacturer of furniture or small household appliances with a network of sub-suppliers for components, materials, and finishes.

What this means: Custom, ad-hoc management is no longer sustainable. You need a unified data collection model—for example, a standardized questionnaire that every supplier completes according to the same set of rules.

Suitable tools:

• Structured questionnaires (online forms or validated templates) with mandatory fields and format validation.
• A completion guide containing examples, a glossary, and defined units of measurement.
• A collection schedule (e.g., semi-annual updates or updates triggered by each new product model).
• A progress tracker: who has responded, who is behind schedule, and what data is still missing.

Risks to manage:

• Inconsistent quality: More established suppliers tend to provide high-quality responses, while smaller ones may struggle. Plan for support and training sessions.
• Verification: With dozens of responses, manually checking every data point becomes costly. Implement automated consistency checks (e.g., flagging out-of-range values, empty fields, or incorrect units).
• Documentary evidence: Request supporting documentation (such as certificates or test reports) from the start, rather than relying solely on self-reported data. Recommendation: Segment your suppliers based on the criticality of the data they provide. Suppliers who provide materials that impact product composition, substances, or carbon footprint require greater attention than those providing marginal components.

Over 50 Suppliers: Portal or Automated Data Exchange

Typical scenario: Major brands in the fashion, electronics, or automotive sectors with multi-tier, often international, supply chains.

What this entails: At this scale, data collection must be industrialized. There are two primary options, which are often used in combination:

1. Supplier portal: Each supplier accesses a dedicated area to upload their data and documents in a predefined format, with immediate validation.
2. Automated data exchange (API / EDI): For larger, more digitized suppliers, data is transferred directly from system to system, without manual intervention.

Suitable tools:

• Supply chain data management platforms featuring onboarding workflows, automated reminders, and dashboards to track data completeness.
• Integrations aligned with European standards for data exchange and interoperability (EN 18216, EN 18223).
• Change-tracking mechanisms to identify who entered or modified a piece of data, and when.

Risks to manage:

• Slow onboarding: Getting dozens or hundreds of companies to adopt a new tool can take months. Plan ahead and prioritize critical suppliers.
• Tier 2 and 3 suppliers: The most challenging data (e.g., the origin of raw materials) often resides beyond the direct supplier. A mechanism is required to cascade requests further down the supply chain.
• Questionnaire fatigue: Suppliers often receive similar requests from multiple clients. Standardized, interoperable formats reduce friction and improve response rates.
• Timeframes: In the battery sector, industry players estimate that building a data infrastructure capable of supporting a "passport" across a complex supply chain can take more than a year. Starting late means risking an inability to bring your products to market.

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Summary Table

Suppliers	Approach	Typical Tools	Main Risk
0	Internal integration	Connected ERP, PLM, and LCA systems	"Hidden" external data left unmapped
1–10	Case-by-case	Shared spreadsheets, direct meetings	Inconsistent formats, over-reliance on specific individuals
11–50	Common model	Standardized questionnaire, completion guide	Uneven data quality, costly manual verification
Over 50	Portal or API	Supplier platform, automated integrations	Slow onboarding, data limited to tiers 2–3

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How to truly answer the question: a practical checklist

1. Start with the passport fields, not your supplier master list. For every piece of information required by your delegated act (or the Battery Regulation), identify who holds that data.
2. Count only those suppliers who provide relevant data. A stationery supplier doesn't count; a supplier of a component containing substances of concern does.
3. Consider subsequent tiers as well. If your direct supplier needs to request data from their own suppliers, the actual number is higher.
4. Factor in growth. If you anticipate new product lines or new markets, opt for the approach suited to the next tier up.
5. Define a common data dictionary before sending out any requests.
6. Assign internal responsibilities for following up, verifying, and updating data.
7. Remember who is legally liable: the responsibility for the passport remains with the economic operator. The quality of supplier data represents a compliance risk for your organization.

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Conclusion

The number of suppliers is not merely a piece of administrative data; it is the key parameter that determines the architecture of your DPP (Digital Product Passport) project. With only a few partners, you can manage processes manually; however, beyond a certain threshold—and in the absence of standardized formats and structured channels—data collection becomes the bottleneck for the entire passport initiative.

With the CEN/CENELEC standards now published, the upcoming European registry, and the February 2027 deadline for the battery passport, now is the time to map your supply chain and select the right approach.