Insights from CircularTech Forum — The Global DPP Community Meets in Cologne

On September 22nd I was in Germany to participate in the CircularTech Forum — the event for the global community around Digital Product Passports (DPPs). Apart from connecting with many interesting people, I walked away with a number of valuable insights. Let me share them with you.

1. As much as 90% of products on the European market might require DPPs in the future

The product groups that receive most attention in the realm of DPPs are batteries and those mentioned in the ESPR Working Plan. However, separate regulations around toys, construction materials, plastic packaging, critical raw materials, detergents, and vehicles also refer to DPPs as a tool for reporting compliance. Moreover, the European Commission’s Single Market Strategy mentions DPPs as the envisioned tool for all product-related compliance reporting in the future, and also refers to DPPs in the Omnibus IV as a tool for simplifying adherence to market regulations. These insights led Maximilian Weinhold from Siemens to mention during one of the panels that 90% of all products in the EU will be required to use a DPP in the future.

2. Design DPP value propositions on the level of separate datapoints

During the same panel, Tilmann Vahle from Quantis — one of the drivers behind the Battery Passport ecosystem — mentioned that each datapoint in the DPP should have its own value proposition. Designing like this prevents data overload and keeps the DPP as small and manageable as possible. It also makes it easier to organise your ecosystem, even within organisations, as it allows you to bring together only the essential value chain for a single datapoint rather than all stakeholders at once.

One point of critique on that view, however, is that it cannot always be determined upfront what the value of a potential datapoint is. For example, consumer organisations might decide to research a specific element of a product value chain due to new insights in the future. So in some cases, including more datapoints could still be valuable. Still, this approach makes the design and implementation of DPPs more resource-effective.

3. Being early is a superpower

Perhaps the most obvious lesson — yet so frequently mentioned it cannot be missed — is to not wait on regulations and standards to start working on DPPs. This point was stressed by Franz Geyer from BMW Group, Dónal O’Regan from Fujitsu/CIRPASS-2, Sven Dahlmeier from Capgemini/Catena-X, and Alexander König from GS1 Germany.

You can improve your data maturity even before knowing all the specific datapoints or technical standards required. Most difficulties come from digitizing supply chains that are still heavily paper-based. Furthermore, the broad categories of datapoints are already known — emissions per product, percentages of recycled materials, and instructions for repair and recycling will be required for every product group for which delegated acts are expected.

4. Invest in DPP readiness of SMEs in your own supply chain

Until now, I have mostly advised SMEs to get ready for DPPs themselves. Gideon Schwich of the recycling company Cylib, however, urged large companies building DPPs to also invest in their own suppliers becoming ready. Franz Geyer of BMW Group even went so far as to say that for SMEs who do not comply with information requirements, it could mean their ‘death sentence’ — which is why they are actively helping them to become compliant.

Dr. Lei Pi of Shenzhen Precise Testing Technology mentioned that for SMEs in China, the whole DPP space is a complete black box. However, the Chinese government has had a long-term strategy to provide them with a Chinese framework for DPP implementation and compliance with Europe’s standards — which could ironically lead to the Chinese market being DPP-ready before European companies.

5. Practical business cases already exist

A significant reduction in the printing of manuals and documents can be achieved through digital access, saving costs and reducing environmental impact. Sales of spare parts are stimulated through repair activities, creating new revenue streams. Step-by-step guides for repairers can be generated by AI based on protected design information, enabling accessible repair without compromising product design secrets.

For recyclers, there is also an increase in revenues from sales supported by verifiable recycling proof — what Martin Mitev from T-Systems called data-driven urban mining. Finally, better access to product information can contribute to a reduction of fire incidents at recycling stations, with a striking example having occurred just two days prior in the UK.

Other Insights

• There is no clarity yet about possible consequences of non-compliance for products produced inside the EU, such as potential fines. For non-compliant products outside the EU it will likely result in a refusal at the border.
• Some key infrastructure at the EU level is not yet in place, such as the carbon footprint delegated act for electric vehicle batteries, the DPP registry, and the web portal.
• If the carbon footprint calculation methodology for EV batteries is required to be captured in law, potentially other products will require the same.
• DPP standardisation with CEN/CENELEC JTC24 is nearing completion, expected for December 2025.
• “Panic has never resulted in good innovation” — Hans-Christian Eberl from the European Commission, on why Europe’s strategic focus is on autonomy and competitiveness rather than solely climate change prevention.
• The DPP Excellence Awards were won by Madaster, Circulor, Narravero, and Path.Era.

What Next for the Global DPP Community?

Now that this year’s event is over, it is time to look forward. Regen Studio will commit itself to helping the community move forward — perhaps by bringing the community to The Netherlands or Brazil. Stay tuned for updates by following us on LinkedIn.

“CircularTech Forum lets the DPP community come together. With strong contributions from the European Commission, the German government, DPP service providers, and DPP adopters.”

— Yvo Hunink, Founder Regen Studio · yvo.hunink@regenstudio.world