One year — the realistic DPP preparation time for a factory

From 18 February 2027, batteries above 2 kWh may only enter the EU market with a digital product passport. Whoever starts preparing today finishes just in time — because field experience says the full process takes not six months but closer to a year. "I would estimate a year rather than half a year," says Zsolt Takács, owner-CEO of ESGinfo.hu and ReadyPass, who sees on manufacturer audits where companies actually stand. (Spoiler: at one or two on a ten-point scale.)

Here is where that year goes.

The seven steps of preparation

1. Requirement assessment

First, understand what the requirement is and whether it applies to your product. This is technical compliance work: it requires a product review and a matrix of which market demands what. At many manufacturers even this step has no owner — periodic review of legal product requirements simply doesn't happen.

2. Specification

Decide and document how you will comply: how the DPP data is produced, who may modify it, in which system. Without this you can neither invest nor select a vendor.

3. Resource allocation

Money, machines, equipment, people. A DPP is not a "downloadable template": it leaves a mark on the production line too.

4. Change management design

If next year the product is painted blue instead of red and the pigment comes from a different source — the product passport must follow. A DPP is not a one-off data submission but a living process, so product-change handling must be designed up front.

5. Marking technology: QR or Data Matrix?

Marking machines must be ordered and the data carrier chosen. DPP data carriers are covered by EN 18220; in practice there are two main candidates:

• the QR code (ISO/IEC 18004) — the standard for consumer smartphone scanning, structured as a GS1 Digital Link (details here);
• the Data Matrix (ISO/IEC 16022) — the proven code for direct part marking (laser engraving, DPM), readable even on tiny surfaces.

The decision is not a matter of taste: customer specifications (e.g. automotive supplier standards), the available marking surface and the laser/inkjet technology determine it together.

6. System integration — a factory is not on the internet

Producing DPP data takes software and software extensions — but manufacturing execution systems (MES) are typically not connected to the internet, and won't be. Data must travel from the production line into the product passport over secure protocols: an integration task between ERP/MES and the DPP platform.

7. Registration, upload, retention

The company must register with the EU as an economic operator, create an account, and link its DPPs to its own identifier. Crucially, the EU does not store the product passports: their availability — for up to ten years, retrievable on regulatory request — must be guaranteed by the business itself, in-house or outsourced. Data security, retention, redundancy: this is an operations question, not a project-closing checkbox.

+1: existing stock

One thing few think of further extends the lead time: products in the warehouse and in transit. Stock manufactured before DPP was planned may need to be marked — or written off.

"It will slip anyway" — is that really a plan?

A significant share of companies is betting that the EU will postpone the deadlines — there is precedent. But: "where there is no pressure, nobody hurries" — and when the pressure does arrive, a one-year lead time cannot be compressed. Meanwhile, the market is not waiting: audit experience shows missing data and invalid certificates lead to rejection in almost every case — there are buyers who won't sign until sustainability data is delivered, and green public procurement already includes conditions like a phone battery retaining 80% capacity after 300 charge cycles.

Not just manufacturers: logistics is in scope too

The DPP has a secondary market: the logistics and commercial chain serving the manufacturers. Passport data follows the goods — freight forwarder, wholesale warehouse (temperature, humidity, handling), delivery, retail — and actors along the chain will have their own data and handling obligations. "It's not the case that 'I don't make batteries, so this doesn't apply to me'" — the freight forwarder has to deal with it as well.