---
title: "Where does your product data live? The check-up that determines the success of your Digital Product Passport"
description: "We analyze three scenarios—centralized, distributed, and unorganized—outlining the risks, priorities, and concrete actions required to align with the ESPR Regulation and harmonized European technical standards."
url: https://www.dppdesigner.com/en/articles/where-does-your-product-data-live
language: en
published: 2026-10-13
updated: 2026-11-05
author: "Corrado Facchini, CTO & Innovation Manager"
publisher: "DPP Designer"
---

# Where does your product data live? The check-up that determines the success of your Digital Product Passport

We analyze three scenarios—centralized, distributed, and unorganized—outlining the risks, priorities, and concrete actions required to align with the ESPR Regulation and harmonized European technical standards.

## Why this question comes before everything else

When a company begins working on a **Digital Product Passport (DPP)**, the temptation is to start with the technology: which platform to choose, which QR code to print, or which service provider to engage. In reality, the decisive question is something else—and far more concrete: **how is product data organized today?**

A passport does not create information out of thin air. It is a digital container that presents—in a structured and interoperable way—data that the company must already possess, such as material composition, origin, certifications, repair instructions, and end-of-life information. If this data is fragmented, incomplete, or difficult to retrieve, the DPP will inherit those same issues—multiplied across every product and every batch placed on the market.

In the DPP Designer guide, this topic appears within the section dedicated to data: it follows the question regarding the number of suppliers involved and precedes the one concerning information already on hand. This sequence is intentional: first, you determine *who* provides the data; next, *where* it is stored; and finally, *what* is already available.

---

## The Regulatory Framework: A Decentralized Passport

The key reference is **Regulation (EU) 2024/1781**, known as the **ESPR** (*Ecodesign for Sustainable Products Regulation*). Two principles within this regulation have direct implications for how data is organized:

1. **Open and interoperable standards.** The passport must be readable and exchangeable across different systems, without relying on proprietary formats.
2. **Decentralized architecture.** Passport data remains with the economic operator—or with the DPP service provider they have appointed. The **European Central Registry**, which will be operational from July 2026, does not store the passports themselves; instead, it indexes their identifiers, making them traceable.

In practical terms, the European Union will not ask you to "upload" data to a common platform; rather, it will require you to **maintain the data yourself**—ensuring it remains reliable, up-to-date, and accessible throughout the entire lifespan of the product. This is why the internal organization of your data is the essential starting point.

### Technical standards have arrived

In 2026, the joint technical committee **CEN-CENELEC JTC 24** published the first European standards to make the Digital Product Passport (DPP) operational, developed at the request of the European Commission (Standardisation Request M/604). The package covers:

| Standard | Scope |
|---|---|
| EN 18216 | Data exchange protocols |
| EN 18219 | Unique identifiers |
| EN 18220 | Data carriers (e.g., QR codes, RFID) |
| EN 18221 | Data storage, preservation, and persistence |
| EN 18222 | APIs for lifecycle management and searchability |
| EN 18223 | System interoperability |

For those tasked with organizing data, the most relevant standards are **EN 18221** (persistence: data must remain available over time) and **EN 18223** (interoperability: different systems must be able to communicate with one another). Both assume that the company knows exactly where every piece of information is located.

### Key deadlines to keep in mind

- **July 2026** – Launch of the European DPP Registry. - **February 18, 2027** – First binding deadline: the battery passport, as stipulated by Regulation (EU) 2023/1542.
- **From 2026 onwards** – Sector-specific delegated acts, in accordance with the ESPR (Ecodesign for Sustainable Products Regulation) 2025–2030 work plan: starting with iron and steel, followed by textiles, tires, aluminum, furniture, mattresses, and other product groups.

Each delegated act will define specific data fields and timelines, with an indicative transition period of approximately 18 months. Eighteen months may seem like a long time, but it is not—especially when the data must first be located, cleaned, and linked.

---

## The three possible scenarios

### 1. Data centralized in a single system

**How ​​it works:** There is a primary reference system—typically a **PIM** (*Product Information Management*) or an **ERP**—that houses all product specifications. Anyone looking for information knows exactly where to find it.

**Strengths**
- A "single source of truth" already exists.
- The passport can be populated via one main integration, rather than many separate ones.
- Responsibilities for data updates are generally clear.

**Risks to consider**
- **Centralized does not mean complete.** A PIM designed for e-commerce may contain descriptions, images, and prices, but often lacks details on material composition, environmental footprint, substances of concern, or disassembly instructions.
- **Insufficient granularity.** Many systems manage data at the *model* level, whereas some passports will require information at the *batch* or *individual unit* level. - **Data from external suppliers.** Even the most well-organized system depends on what is received from the supply chain.

**Operational Priorities**

The guidance here is clear: **distributed data requires a common data model before it can feed into the passport.** In practical terms, this means:

1. **Defining a common data model** that describes the entities (product, component, material, batch, supplier, certificate) and the relationships between them.
2. **Establishing a reconciliation key**—a unique identifier shared across systems—consistent with the requirements of the EN 18219 standard.
3. **Mapping each field in the passport** to the system that "owns" it, thereby avoiding duplication.
4. **Choosing an integration architecture**: either an intermediate layer (such as middleware or a data hub) to aggregate the data, or direct integrations between the various systems and the DPP (Digital Product Passport) platform.
5. **Transforming documents into data**: extracting key information (issuing body, expiration date, scope) from certificates and converting it into a structured format.

### 3. Unorganized Data

**The current state:** There is no reference system. Information is scattered across **Excel files saved on individual computers**, emails, personal folders, and—most significantly—within people's own memories.

This is a common situation in small businesses and many companies throughout the supply chain. It is important to state this without judgment: for years, there was no mandate requiring such information to be structured.

**Risks that should not be underestimated**
- **Dependence on individuals.** If someone who holds key data changes roles or leaves the company, that information is lost.
- **Inability to ensure persistence.** The ESPR (Ecodesign for Sustainable Products Regulation) and the EN 18221 standard require data to remain available over time—potentially for years after a product has been placed on the market.
- **Errors and inconsistencies** arising between different files that describe the same product. - **Difficulty in responding to customers.** Downstream companies that need to create their own product passports will request structured data from their suppliers.

**Operational priorities**
1. **Inventory** existing data: identify which files exist, where they are located, and who is responsible for updating them.
2. **Select a reference system**—even a simple one—provided it is unified and shared across the organization. Some DPP (Digital Product Passport) solutions include a basic product repository.
3. **Start with a limited scope**: focus on a single product line or family, rather than the entire catalog.
4. **Establish basic governance rules**: define who creates, validates, and updates the data.

While this approach may take more time, it offers a distinct advantage: you can design your data organization with the product passport in mind from the very beginning, rather than having to retrofit systems originally built for other purposes.

---

## Quick Comparison

| | Centralized | Distributed | Unorganized |
|---|---|---|---|
| **Typical example** | PIM or ERP containing all product records | PLM + MES + shared folders | Local Excel files, emails |
| **Integration effort** | Low | Medium-to-high | High (a system must be built first) |
| **Main risk** | Missing fields | Inconsistent identifiers | Loss of data and knowledge |
| **First step** | Gap analysis of data fields | Common data model | Inventory and selection of a reference system |

---

## Checklist: Five questions to ask yourself today

1. Is there a **unique product identifier** recognized by all company systems?
2. For every piece of information required by the product passport, is it clear **which system or individual** is responsible for it?
3. Is the data managed at the **required level of detail** (e.g., by model, batch, or individual item)? 4. Does the information from **suppliers** arrive in a structured format, or as documents that require interpretation?
5. Can we ensure that the data remains **accessible and up-to-date throughout the entire product lifecycle**?

If the answer to two or more of these questions is "no" or "I don't know," then data organization is the first area that needs to be addressed—even before selecting a platform.

---

## Conclusion

The Digital Product Passport is often framed as a technological project, but it is, first and foremost, a **data project**. The decentralized architecture mandated by the ESPR places the responsibility for storing and maintaining information squarely on companies: those starting with centralized data will primarily need to supplement it; those with distributed data will need to unify it via a common model; and those who have not yet organized their data will need to build the necessary foundation.

In all three cases, answering the question "How is our data organized today?" with complete honesty is the fastest way to estimate the timelines, costs, and priorities for your journey toward the DPP.

## Sources

- [DPP Designer – How is this data organized today? (Guide, question 13 of 22)](https://www.dppdesigner.com/it/guida/data-organization)
- [Regulation (EU) 2024/1781 (ESPR) – EUR-Lex](https://eur-lex.europa.eu/eli/reg/2024/1781/oj/ita)
- [DPP Designer – ESPR Regulation (EU 2024/1781): the complete guide](https://www.dppdesigner.com/it/normativa-espr)
- [DPP Designer – Digital Product Passport sectors and deadlines](https://www.dppdesigner.com/it/sectori)
- [CDX – First European Standards for the Digital Product Passport Published](https://public.cdxsystem.com/en/web/cdx/w/first-european-standards-for-the-digital-product-passport-published)
- [Fraunhofer IPK – The Standards for the Digital Product Passport are Here](https://www.ipk.fraunhofer.de/en/media/media-information/20260601-die-standards-fuer-den-digitalen-produktpass-sind-da.html)
- [Think WIoT – CEN-CENELEC Publishes Six Standards for the EU Digital Product Passport](https://wiot-group.com/think/en/news/cen-cenelec-six-eu-dpp-standards-en-18xxx/)
- [EU Transition Pathways – Commission Implementing Decision (EU) 2026/1736 on DPP harmonized standards](https://transition-pathways.europa.eu/retail/policy/commission-implementing-decision-eu-20261736-harmonised-standards-digital-product)
- [Renoon – Digital Product Passport: latest updates and next developments](https://www.renoon.com/blog/digital-product-passport-latest-updates-the-next-developments-to-watch)
- [Certivo – EU Digital Product Passport Registry: July 2026 Readiness Guide](https://www.certivo.com/blog-details/eu-digital-product-passport-registry-july-2026-readiness-guide)
- [Bluestone PIM – Digital Product Passport Timeline](https://www.bluestonepim.com/blog/digital-product-passport-timeline)