Digital product passports (DPP) are about to become a hard requirement in the EU. Batteries are the first product and will become mandatory by February 2027, followed shortly by textiles, steel, aluminum, and information and communication technology (ICT) hardware.
These requirements will not arrive simultaneously with early indicators pointing to adoption for some sectors as soon as later this year, which means the first wave of non‑battery products could face an actual deadline of mid‑to‑late 2027, following a countdown period. As a result, it is now a very important time for businesses to adapt to this new tender framework.
The impressive aspect about these passports is that they won’t be simply a static PDF file submitted with applications. Instead, they’re machine‑readable records that are designed to plug directly into procurement evaluation systems and eventually customs checks via an EU central registry that’s still in development.
In this article, we take a closer look at how digital product passports will impact tendering, how buyers will use them, and the scoring implications that accompany them.
The mandate that moves first
The first milestone in implementing DPP is scheduled for 18 February 2027.
- Every EV battery, industrial battery over 2 kWh, and light‑transport battery that will be sold in the EU will need a passport. It has to be accessible via a QR code and tied to a unique identifier.
There will be other obligations, such as verified site‑specific carbon footprints, recovery rates, and sourcing documentation. In theory, this will allow multi‑tier supply chains to evidence real, item‑level data rather than averaged figures.
- Textiles and some metals will be on a slightly different path.
The European Commission is expected to adopt delegated acts for these sectors later this year, which is when the standard 18‑month countdown will begin for these industries. This means that the first compliance deadlines could be in mid‑to‑late 2027 for early product categories, with others following from 2028 onwards.
For textiles, the EU plans to start with a “minimal and simplified” DPP format, giving smaller suppliers a softer landing before the full model arrives closer to 2030.
- Construction products pose a longer‑term challenge.
Here, DPP rules won’t apply until 18 months after the EU’s central system goes live and harmonized standards are in place. That launch date is still fluid, with 2026 being at best optimistic, with the actual deadline likely to be later. Once it does go live, manufacturers face long record‑keeping horizons: 10 years of maintained records, with data remaining accessible for 25 years.
How buyers will actually use this
Naturally, buyers are interested in awarding contracts on verifiable data rather than promises, which structured product passports will enable. It’s fair to assume that they will considerably cut review times, reduce protest risk, and allow evaluators to utilize an official record instead of a marketing copy.
As central registries come online, checking the declared footprint or recycled content of a product will involve a quick lookup and, therefore, considerably reduce any reservations or doubts for buyers.
The way we see it, two mechanics will have a massive impact on evaluation behaviour.
1. Firstly, data verification.
The EU’s central registry, once it becomes operational, is expected to allow public and restricted data checks, with eventual links to customs systems. While customs integration remains on the drawing board, the EU’s strategy is clear – evaluators will move from trusting the claims made about a product to validating structured data against official sources.
2. Second, granularity.
Battery passports will require per‑product identifiers, QR‑based access, and a model that separates public and private layers with the QR physically affixed when possible. Harmonized standards, due by December 2025 from CEN/CENELEC JTC 24 (a Joint Technical Committee set up by Europe’s two standardization bodies – CEN for general standards, and CENELEC for electrotechnical), are intended to bring this logic to other sectors.
The takeaway? Buyers will start to expect structured, searchable product data they can interrogate rather than dense prose that is buried in annexes. Once this expectation sets in, “narrative‑only” documentation is going to feel incomplete. And once those mechanics take hold, the knock‑on effects will extend to how tenders are scored. Some of the shifts are obvious, but others only emerge when you look closely at how evaluators will handle structured, verifiable product data in practice.
Tender scoring implications that aren’t obvious at first glance
When digital product passports enter the mix, a few scoring dynamics will start to shift, and not all of these are obvious from the regulations alone.
1. Firstly, technical quality will become easier and faster for evaluators to verify.
If DPP fields are integrated directly into the Enterprise Resource Planning (ERP) or Product Lifecycle Management (PLM) systems, they will create a traceable chain that runs from the bill of materials right through to end‑of‑life handling. That kind of structured, end‑to‑end visibility doesn’t just tick a compliance box; it signals to a buyer that the supplier has tight operational control over their production and supply network.
2. Secondly, sustainability points stop being awarded on the strength of the narrative and start to become evidence‑driven.
In the battery sector, third‑party‑verified carbon footprints are already a hard requirement, and textiles and metals are expected to follow the same staged approach. Once those criteria migrate into scoring templates, the conversation shifts from “we have sustainability initiatives” to “here are verified numbers you can plug into your scoring model.”
3. Thirdly, risk assessment takes on a new dimension - data governance.
The DPP architecture demands unique identifiers for each product, operator, and facility, and those IDs have to remain consistent across any updates. In practice, that consistency becomes a proxy for reliability: evaluators will start to read well‑governed, accurate passport records as a sign the supplier is organised, trustworthy, and less likely to cause downstream compliance problems.
All in all, these implications raise the bigger question: it’s not if buyers will integrate automated DPP checks, but when they will quietly move from treating them as differentiators to making them hard eligibility gates? Once that switch happens, being “DPP‑ready” won’t earn you extra points - it will simply decide whether your bid is opened at all.
Where the operational friction will show up
The mechanics of DPPs sound straightforward on paper, but in practice, there are a few points in the chain where implementation will bite - and where unprepared suppliers will feel the drag first.
Identifier management
Every eligible product will require a unique serial‑level ID that is linked to a QR code or, in some cases, an RFID tag. That identifier must tie back to your master data system without any gaps. Sounds simple - until you scale it across thousands of stock keeping units (SKUs), multiple production sites, and replacement parts. Miss a link, and you create orphan records that evaluators can’t verify.
Data partitioning
Each passport carries both public and restricted fields. Keeping those clearly separated while reconciling them to the same trusted source system is a technical and governance challenge. Get it wrong, and you either leak commercially sensitive data or present inconsistent records - either mistake will erode buyer confidence.
Upstream onboarding
This is the tricky one in sectors like textiles, where supply chains stretch across multiple countries and tiers. Collecting standardized data from every link - including small upstream players with limited IT capacity - will take time. That’s why the EU has built a “minimal DPP” entry phase for textiles, which gives suppliers a ramp‑up period before the full requirement lands closer to 2030.
Standards drift
The harmonized package from CEN/CENELEC JTC 24, due in December 2025, will codify the technical “how,” but anyone used to IEC or ISO standard cycles knows that late adjustments will happen. Even minor changes to data structure or access protocols can ripple into your deployment plans - especially if systems were locked down early. Building in a bit of technical slack now will save expensive rework later.
Where advantage accrues for tender‑active organizations
Some parts of this system are moving faster than others - and that pacing will create openings for suppliers who know where to lean in first. The rollout rhythm and the way the EU’s central registry is being designed will both reward going deep before you go wide.
- Batteries will be the proving ground.
February 2027 is locked in, and it’s a hard, public date. Anyone in that space will have to own the details: serialization at the product level, managing the logistics of getting QR codes onto physical units, and making sure those codes interface cleanly with the registry. The organizations that iron out those kinks early won’t just meet compliance - they’ll know how to make the process repeatable for other categories.
- Textiles and certain metals will be the early next wave.
For these, the EU has signaled a “minimal” initial passport, which is likely to cover basics such as composition, recycled content, and core traceability points. That first version is deliberately lighter to give smaller suppliers breathing room - but for those ready to collect and structure this data now, it’s a head start. When the scope expands, you won’t be racing to retrofit your systems; you’ll be refining what’s already working.
- Construction products are the long‑term play.
Their DPP obligations don’t kick in until the central system goes live and harmonized standards are in place - dates that could land later than some expect. But the record‑keeping horizon is long: 10 years’ maintenance, 25 years’ accessibility. Getting archival and retrieval processes in place now isn’t over‑preparation; it’s making sure you can retrieve product histories long after the project manager has moved on.
And across all of these, one principle will shorten headaches down the line: pre‑validate your product passports against the registry schema before tenders close. That way, you know your data will pass when it matters, avoiding post‑award delays, disputes, or costly retrofits under contract pressure. In a market that is shifting toward structured, verifiable data, having that assurance before you even submit can be the quiet advantage that wins you the contract.
The bottom line
DPPs will move tendering toward a simpler rule: if it’s structured and verifiable, it counts. The advantage goes to suppliers that treat DPP readiness as core infrastructure - clean IDs, governed data, upstream onboarding - rather than a last‑minute checklist.
Buyers will verify, not infer; scoring will lean on numbers, not narratives; and over time, passport compliance will shift from a differentiator to an eligibility gate.
The practical move now is focused depth: pilot one product line, wire data to the coming schema, rehearse registry interface, and pre‑validate before submission.
Do that, and you will shorten reviews, reduce dispute risk, and build credibility you can reuse. Leave it late, and you’ll be translating claims into evidence under contract pressure.
The market is converging towards the same destination; getting there early is what will feel like an advantage.