The Digital Product Passport Is a Master Data Problem, and It Isn’t Only Europe’s

When US manufacturers hear about the EU’s Digital Product Passport, a common first reaction is that it’s a European rule for European companies. That reaction is understandable, and it’s also likely to cause trouble.

The passport applies to products sold in the EU, wherever they’re made. It also pulls data requests down the supply chain to component makers who may never ship to Europe themselves. Meanwhile, several US rules are asking manufacturers for the same kind of detailed, traceable product information. The companies best prepared for all of it won’t be the ones with the best compliance reports. They’ll be the ones with the cleanest product and supplier data behind those reports.

What the Digital Product Passport actually is

The Digital Product Passport comes from the EU’s Ecodesign for Sustainable Products Regulation (ESPR). The European Commission describes it as “a digital container for products, components, and materials” that stores information supporting sustainability, circularity and legal compliance. Buyers, repair shops, recyclers and regulators reach that information through a data carrier on the product, such as a QR code.

Batteries come first. Starting February 18, 2027, electric vehicle batteries, industrial batteries and batteries for light vehicles like e-bikes and e-scooters must carry a passport. The Commission lists the kinds of data it will hold:

• Battery identification and technical characteristics
• Manufacturer and economic operator details
• Performance and durability information
• Information supporting repair, reuse and recycling
• Sustainability and circularity data

More product groups are scheduled to follow under ESPR, including iron and steel, textiles, tires, furniture and information and communications technology (ICT) products. The details will differ by category, but the pattern is the same: a structured, product-level record that stays accurate over the product’s life.

Why it reaches US manufacturers

There are two main ways the passport lands on a US company’s desk.

You sell into the EU. The requirement follows the product to market, not the company to its headquarters. If your products, or products built by your customers, are sold in the EU, someone in the chain is responsible for a compliant passport.

Your customers need your data. Passports describe finished products, but finished products are built from components. A battery maker assembling a passport needs accurate material, origin and specification data from the companies that supply its cells, electronics and housings. That includes semiconductor and electronic component suppliers. Those requests usually arrive as structured data templates with firm deadlines, not casual emails.

For many US manufacturers, the second path is the more likely one. You may not own a single passport, but you may be asked to feed dozens of them.

The US is asking similar questions

Even companies with no EU exposure are seeing data requests with the same shape.

Right to repair. A growing number of states now require manufacturers to give consumers and independent repair providers access to parts, tools, technical documentation and, in some cases, firmware and diagnostic data. Washington’s law took effect January 1, 2026, Connecticut’s on July 1, 2026, and Texas’s on September 1, 2026. They join earlier laws in states including New York, California, Minnesota, Colorado and Oregon, and some form of right-to-repair legislation has been introduced in all 50 states.

PFAS reporting. Under the Toxic Substances Control Act (TSCA), the EPA requires companies that manufactured or imported PFAS in any year from 2011 through 2022 to report on those substances. The EPA has delayed the start of the reporting window while it finalizes a revised rule, which it plans to issue later in 2026. The dates are moving, but the need to trace what substances went into which products isn’t going away.

These rules come from different agencies with different goals. Underneath, they ask for the same thing: accurate, traceable information about what’s in a product, where it came from and how to maintain it.

Why this is a data problem, not a reporting problem

Most manufacturers already have much of the data these rules require. The trouble is where it lives. Material declarations sit in a supplier portal. Specifications live in PLM. Country of origin is in the ERP. Repair documentation is a set of PDFs on a shared drive. Substance data might be in an email from a supplier three years ago.

A reporting tool can format that information into a passport or a regulatory filing. It can’t fix a part that exists twice with different weights, a supplier listed under three names, or a material declaration attached to the wrong revision. If the underlying records conflict, every output built on them inherits the problem.

That’s why the passport is best treated as a master data management challenge. Compliance attributes need to be governed parts of the product record, with clear owners, validation rules and links to the related supplier and location records. Similarly, Stibo Systems notes that passports depend on data across several domains, including product, supplier, location, packaging and asset data.

Once that foundation is in place, a new requirement becomes a question of mapping existing, trusted data to a new output rather than starting another data-gathering project.

Where to start

Deadlines differ by product and rule, but the early steps look the same for most manufacturers.

1. List what’s being asked for. Collect the attributes each relevant requirement calls for, from EU passports to state repair laws to PFAS reporting. You’ll likely find a lot of overlap.
2. Find where each attribute lives, and who owns it. Map every attribute to its current source system and a named owner. Gaps in ownership tend to point directly at gaps in quality.
3. Connect product and supplier records. Origin, material and substance data usually starts with suppliers. Linking supplier records to the parts they provide makes it possible to trace a finished product back to its inputs.
4. Standardize identifiers and classification. Consistent part numbers, units and product classes make every downstream request easier. Standards like ETIM give technical products a shared structure that trading partners already recognize.
5. Plan for change. Requirements will keep evolving, as the PFAS timeline shows. A flexible data model and governed workflows make it easier to add new attributes without rebuilding what’s already there.

Getting ahead of the next request

The EU’s battery passport deadline is less than five months away, and US requirements keep adding up. Companies that treat each rule as its own project will keep repeating the same data work. Companies that build one trusted record for their products, materials and suppliers can respond to the next request, wherever it comes from, with far less effort.

Ready to get your product and supplier data ready for Digital Product Passports and the US requirements coming next? Contact us to build a governed master data foundation with Sitation and Stibo Systems.