DPP, REACH, RoHS: Product compliance can no longer be left to chance in 2026
The digital product passport will be rolled out in waves by industry starting in 2027. Here’s what you need to start collecting now—and why it all comes down to the product repository.
Product compliance used to be stored in a binder, managed by a single person, and pulled out during inspections. The European regulation on the eco-design of sustainable products is changing the nature of the problem: compliance data is becoming product data—published, structured, and accessible throughout the product’s lifecycle. It’s moving out of the file cabinet and into the catalog.
What Is a Digital Product Passport?
The Digital Product Passport (DPP) is a structured set of information associated with a product and accessible via a digital medium, typically a code affixed to the item or its packaging. It includes identification, composition, origin, sustainability, repairability, end-of-life instructions, and compliance documents.
The key point for a distributor: this information isn’t generated by you—it’s generated by your suppliers. Your job is to collect, structure, store, and republish it—in other words, it’s product data management.
The timeline as it is taking shape
| Deadline | Scope |
|---|---|
| 2026 | Launch of the European registry, prior to the first sector-specific requirements |
| February 18, 2027 | Full battery passport |
| Sometime in 2027 | Textiles and apparel, furniture and mattresses, tires, detergents; steel and aluminum to follow |
| 2028–2029 | Electronics and computer equipment, followed by other categories with a high environmental impact |
Two possible interpretations. The first: “We still have a year.” The second, more accurate one: collecting data from dozens of suppliers takes between twelve and twenty-four months. Organizations that start in early 2027 will be behind schedule.
What already existed—and isn’t going away
- REACH: Chemical substances, with a requirement to provide information on substances of very high concern above a certain threshold, including for distributors.
- RoHS: Restriction of hazardous substances in electrical and electronic equipment.
- CE marking and declaration of conformity: documents to be retained and produced upon request.
- WEEE: a system for the collection and recycling of end-of-life electrical equipment.
The DPP does not replace any of these. It makes part of this information publicly accessible and structured, which is a fundamental difference: incorrect data in a file remains hidden, while the same incorrect data in a public product passport can be verified immediately.
Why this is critical in the product repository
Compliance data has three characteristics that make it unmanageable in a spreadsheet:
- It is versioned. A composition changes, a certification is renewed, a supplier is replaced. You need to know what was true on the date each batch was placed on the market.
- It includes attachments: safety data sheets, declarations, test reports. These documents must remain linked to the product reference and its version.
- It must be republished across multiple channels: websites, marketplaces, B2B customer portals, and public product passports. The same data, in different formats.
In other words: this is exactly the definition of a product repository, with an additional traceability requirement.
What You Need to Start Collecting Right Now
- The unique identification of each SKU: global identifier, manufacturer’s part number, link to the actual supplier—not the intermediary.
- Material composition and origin, in a structured format rather than free-text. This is the most challenging field to retroactively capture.
- Existing compliance documents, scanned and linked to the product SKUs, along with their validity dates.
- Contact information for the responsible business operator for each imported SKU.
- Sustainability and repairability data, when provided by the supplier: warranty period, parts availability, repair instructions.
None of these five points depends on the publication of the final text. All will be required, regardless of the exact format of the passport for your category.
The practical solution: automate supplier data collection
The bottleneck isn’t storage—it’s acquisition. Sending follow-up emails to sixty suppliers to obtain safety data sheets in PDF format isn’t scalable.
What works: a structured import channel—file upload, data exchange, interface—with mapping per supplier and automatic follow-ups for missing fields. This is one of the few areas where AI-driven automation offers immediate and measurable benefits: reading diverse documents and extracting structured fields, with human validation for uncertain cases.
Frequently Asked Questions
Am I affected if I don’t manufacture anything?
Yes, as long as you place a product on the European market—including by importing from a third country or selling under your own brand. The distributor has information and record-keeping obligations.
What happens if my supplier doesn’t provide the data?
This is the real operational challenge, and it must be addressed both contractually and technically: incorporate the provision of compliance data into the terms of purchase, and treat a supplier who fails to provide it as a business risk, not just an administrative one.
Is a specialized tool required?
Not necessarily a tool dedicated to compliance, but a product information management (PIM) system capable of handling versioned attributes, attachments, and an audit trail. Some PIMs handle this data as native attributes rather than as an extension—this is the case with Pixee PIM, where compliance is included in the model rather than offered as an option.
Where to start with a limited budget?
Start with an inventory: Which categories in your catalog are affected by the first waves, and what percentage of the required data do you already have? This inventory takes a few days and turns a daunting task into a work plan.
Conclusion
Product compliance is no longer a peripheral legal issue but has become a data quality requirement, just like the completeness of sales attributes. The good news is that these two areas largely overlap: the product database that makes you visible to agents is also the one that will ensure your compliance.
See also: Why Product Data Is Becoming the No. 1 Asset. To assess your regulatory exposure category by category, let’s discuss it.