Digital Product Passport Software: Supply Chain Data Collection for DPP Compliance

The EU's Digital Product Passport (DPP) regulation requires manufacturers, importers, and marketplace operators to attach a machine-readable data record to each product they place on the EU market. That record must include material composition, chemical substances of concern, recycled content percentages, carbon footprint, repairability scores, and supplier identifiers — traced across every tier of the supply chain. Generating the QR code that carries this data is straightforward. Getting the underlying data from dozens or hundreds of suppliers is not.

Most DPP software tools focus on the last step: packaging compliant data into a carrier format and registering it with the EREVS digital registry. The gap they don't solve is upstream — collecting verified, structured data from Tier 1, Tier 2, and Tier 3 suppliers who have never been asked for it before. That is the problem Brightest is built to solve.

Why supplier data collection is the hardest part of DPP compliance

The ESPR regulation (EU 2024/1781) and the Battery Regulation (EU 2023/1542) specify granular data fields that must appear in a product's Digital Product Passport. For a textile product, that includes fiber composition by weight, country of origin per processing step, chemical treatment records, and end-of-life instructions. For a battery, it extends to cell chemistry, state of health, carbon footprint per kWh, and due diligence on conflict minerals.

This data does not exist in one place. It lives across supplier ERP systems, material safety data sheets, factory production records, and lab certification documents — in different formats, languages, and levels of completeness. Collecting it manually via spreadsheets and email is the approach most companies start with. It does not scale once the regulation kicks in across hundreds of SKUs.

The compliance challenge is compounded by multi-tier traceability. An EU importer's DPP obligation does not stop at their direct supplier. ESPR's traceability requirements — and the Battery Regulation's supply chain due diligence rules — extend to sub-suppliers and raw material sources. A company that can collect data from Tier 1 but not Tier 2 or Tier 3 has a compliance gap that only becomes visible when the product is already on the market.

What DPP compliance software needs to handle

• Structured data collection from supplier networks — outreach, forms, and follow-up across Tier 1, Tier 2, and Tier 3 suppliers without requiring suppliers to install new software
• ESPR-specific data field mapping — material composition, hazardous substance declarations (SCIP-compatible), recycled content, carbon footprint per unit, and repairability/disassembly data
• Battery Regulation data schema support — cell chemistry, state of health, supply chain due diligence, and per-kWh carbon footprint for industrial and EV batteries
• Document and certificate management — REACH declarations, conflict minerals reports, factory certifications, lab test results linked to specific SKUs
• Data validation and completeness checking — automated flagging of missing fields before submission to the EREVS registry
• Unique Product Identifier (UPI) generation — conforming to the ISO/IEC 15459 carrier format required by ESPR Article 11
• Integration with existing ESG reporting data — reuse of Scope 3 emissions data, supplier assessments, and LCA results already collected for CSRD or other frameworks

How Brightest enables DPP data compliance

Brightest is an AI-powered ESG data collection platform that automates supplier outreach, data normalization, and structured storage at scale. The same infrastructure that handles Scope 3 emissions data collection from supplier networks is the infrastructure that maps to ESPR's DPP data requirements.

Rather than building a separate DPP data collection workflow alongside an existing ESG program, Brightest unifies them. Material composition data collected for a product's DPP is the same data used to calculate Scope 3 Category 1 purchased goods emissions. Chemical substance declarations collected for ESPR compliance also satisfy REACH reporting requirements. Carbon footprint data collected for the DPP satisfies both ESPR Article 7 requirements and CSRD Scope 3 disclosures.

The platform handles multi-tier supply chain sustainability data collection without requiring sub-suppliers to adopt new software. Suppliers receive structured data requests via email or web form, with AI-assisted data extraction from documents they already have — material safety data sheets, factory certifications, LCA reports. Brightest normalizes responses into a consistent schema, flags gaps, and maintains an audit trail for regulatory review.

For companies already using Brightest for CSRD, Scope 3, or supplier ESG assessments: DPP data collection is a configuration layer on an existing data program, not a greenfield implementation.

Who needs DPP compliance software

DPP requirements apply by product category, phased in from 2026 through the early 2030s. The first categories in scope are batteries (Industrial, LMT, EV — Battery Regulation from 2026), followed by textiles, electronics, furniture, iron and steel products, aluminium, tyres, paints and lubricants, and chemicals under successive ESPR delegated acts.

• EU manufacturers placing regulated products on the EU market — responsible for creating and maintaining the DPP
• Importers and brand owners sourcing from non-EU manufacturers — bear the same DPP obligation as manufacturers when the manufacturer has no EU authorised representative
• Marketplace operators selling regulated products online — prohibited from listing products that lack a valid DPP once category-specific regulations take effect
• Sustainability and compliance teams at companies in scope for CSRD or existing voluntary reporting frameworks, who need to unify DPP data collection with their existing ESG data program

DPP and ESG: one data program, not two

The overlap between DPP data requirements and ESG reporting data is substantial. ESPR's mandatory carbon footprint per unit feeds directly into Scope 3 Category 1 (purchased goods) calculations. Material composition and recycled content data overlap with circular economy disclosures under CSRD's ESRS E5. Chemical substance declarations map to REACH reporting and ESRS pollution disclosures.

Companies that build a separate DPP data collection system in isolation from their ESG data program end up collecting the same supplier data twice — at significant cost and with inconsistencies between the two records. Brightest is designed to prevent that: a single data collection exercise produces outputs that satisfy DPP, CSRD, Scope 3, and supply chain due diligence requirements simultaneously.

For companies currently assessing their DPP readiness alongside broader EU compliance requirements, our EPR compliance guide and DPP technical requirements overview provide the regulatory context behind what data fields are mandated and why.