"We don't have to comply, we ain't in the EU!"
That's what I heard from a UK manufacturer last week when I brought up Digital Product Passports. And they're right, technically we don't have to comply as a nation. But as a nation of manufacturers we absolutely MUST comply if we want the UK economy to thrive and if we care about the environmental and economic future of the continent.
Let me explain why....
The EU is still our biggest customer
Here's a number that should make anyone in UK manufacturing sit up. In 2024, UK exports of goods and services to the EU totalled £358 billion. That's 41% of everything we export. Nearly half. Germany, Netherlands, France, Ireland... these are our bread and butter markets.
So when the EU introduces a regulation that essentially says no Digital Product Passport, no market access... and that's exactly what the Ecodesign for Sustainable Products Regulation (ESPR) does... you can't just shrug it off because we left the bloc. That's not a regulatory opinion, that's a commercial decision. And it's one that could cost you big time.
The ESPR applies to any product placed on the EU market regardless of where it was manufactured. UK, USA, China, Australia... doesn't matter where your factory is. If your product ends up on a shelf or in a supply chain within the EU, it needs a Digital Product Passport. No exceptions.
And at the same time I read from our friends over at GS1 that manufacturers stand to lose £1.5 million per year if they don't comply with Digital Product Passport requirements. Besides the economic impact, the environmental and social impact is huge. The EU is getting serious about the damage we do to our environment and our society, and the DPP along with these regulations addresses these issues head on.
What actually is a Digital Product Passport?
For those still catching up on all this, a Digital Product Passport is basically a structured digital record tied to a unique product identifier... usually accessed via a QR code on the product or its packaging. It holds verified, machine-readable data about the product's composition, where it came from, its environmental footprint, how durable it is, whether it can be repaired, its compliance status and a lot more.
Think of it as a product's entire life story. From raw materials all the way to recycling. Regulators can access it, supply chain partners can access it, and consumers can access it too.
A lot of people think Digital Product Passports are just about the environment. But they're not just that. They go much deeper.
The first wave of mandatory DPPs kicks in from February 2027 for batteries (EV, industrial above 2 kWh, and light means of transport), with textiles, electronics, construction products, iron, steel, aluminium, furniture and more following through to 2030 under the ESPR's first working plan.
And if you think this is years away and you can worry about it later... batteries are less than twelve months out. The time to prepare was yesterday.
Want to sell in the EU? Prove your product hasn't caused harm
This is the part that really gets to me.
Want to place a product on the EU market? Well, prove it hasn't damaged the environment. You want to operate as a large organisation in the market? Well then show your due diligence that your supply chain isn't using forced or child labour.
The Corporate Sustainability Due Diligence Directive (CSDDD) requires companies with over 1,000 employees and €450 million turnover to conduct mandatory due diligence on human rights and environmental impacts across their entire value chain... upstream and downstream. And the EU Forced Labour Regulation, which came into force in December 2024, goes even further... any product found to have been made using forced labour at any stage of its supply chain can be banned from the EU market entirely.
Under the new Battery Regulation (EU 2023/1542) for example, you must ensure your supply chain meets these standards. And going a step further, if you're a large economic operator then you need to carry out a thorough supply chain due diligence... and have it third party verified. No compliance, no access to the EU market.
Watching all those documentaries that show mining in developing countries, the poor practices, the ages that are forced to work there. The cobalt mines where children dig with their bare hands. The garment factories with impossible conditions. It beggars belief why we had to wait so late to address these issues.
The phone in your pocket, or the very one you're holding right now reading this. That laptop in front of you. How do you know it didn't come at the cost of forced or child labour? You don't. We place our blind trust in big names, elegant logos, dazzling marketing because "how can I check everything, it's on the market right??" Wrong.
Far too long have we gone without transparency, without accountability and traceability. But this is changing. Not just in Europe but the whole world is watching and the Brussels effect and benefits of what's going on will prevail across the globe. The DPP is one of the mechanisms making it enforceable... because when every product carries a verified digital record of where its materials came from and who was involved in making it, hiding behind ignorance of your supply chain stops being an option.
The EU isn't messing about with enforcement either
This isn't just words on paper. The ESPR establishes a DPP registry connected directly to the EU's customs systems. Products without a valid passport won't just face fines... they can be stopped at the border. Customs authorities across the EU will have direct access to verify compliance before goods are released for circulation.
So let's think about what happens when your competitors are DPP-ready and you're not. EU importers and distributors will favour the supplier who can hand over a compliant, verified digital passport without friction. The one who can't? They get dropped from the tender list. Simple as that.
Consumers are demanding this too
And it's not just regulators pushing this. Younger generations aren't just passively hoping for a better world, they're actively voting with their wallets. Research consistently shows that the majority of Gen Z and Millennial consumers factor sustainability into their purchasing decisions, they research supply chains, they look for certifications, and they'll pay more for products from brands they trust.
And critically... they'll walk away from brands that don't meet their standards. Studies show a significant majority of Gen Z consumers have boycotted or stopped purchasing from companies exposed for unethical practices. This isn't a niche market segment. Gen Z alone influences hundreds of billions in global spending annually.
The demand isn't complicated. More fairness. More transparency. More balance. And frankly... they're right to demand it. And so they should!
So what is the manufacturer really saying?
Let me go back to that manufacturer who told me "we don't have to comply."
Let me translate what that statement actually means in practice. The manufacturer that dismisses the idea of compliance with DPPs... not only in the UK, in the USA, China, Australia... whoever! Might as well respond by saying:
- "We don't mind our revenue decreasing"... because losing access to 41% of UK export markets is the inevitable consequence of non-compliance.
- "Environmental issues in our supply chain are not our priority"... because DPP compliance requires transparent data on environmental impact and ignoring it means accepting that your products may carry a hidden environmental cost you're unwilling to address.
- "Social issues in our supply chain are not our concern"... because the due diligence requirements behind these regulations exist specifically to root out forced labour, child labour and exploitation.
Sounds harsh? Well that's the reality.
This isn't just an EU thing
And let's be clear... the regulatory direction of travel is global.
The EU's ESPR and Battery Regulation are setting the template that other jurisdictions are watching closely. Similar transparency and traceability frameworks are being explored or implemented across multiple markets. The EU has historically been the global standard-setter for product regulation... from CE marking to REACH chemicals regulation... and the DPP is following the same trajectory.
Manufacturers anywhere in the world... the UK, the US, China, Australia... who build DPP compliance into their operations now aren't just preparing for EU market access. They're future-proofing their businesses for a world where product transparency isn't optional. It's table stakes.
What UK manufacturers should be doing right now
If you're a UK manufacturer reading this and feeling the urgency... good. Here's where to start:
Audit your EU exposure. What percentage of your products end up on the EU market, either directly or through your customers' supply chains? If the answer is anything above zero, DPP compliance applies to you.
Map your supply chain data. The DPP requires verified information on materials, sourcing, environmental footprint and more. If that data doesn't exist in a structured, accessible format today, you've got work to do.
Understand your timeline. Battery passports are mandatory from February 2027. Textiles, construction products, electronics and other categories follow under the ESPR working plan. Know your deadlines. Build backwards from them.
Engage with DPP solution providers. You don't need to build this from scratch. There are platforms designed specifically to help manufacturers create, manage and maintain compliant Digital Product Passports with integrations into existing product information management systems.
Talk to your industry body. GS1, the global standards organisation, has published extensive guidance on DPP implementation using internationally recognised identification standards. Their frameworks are directly aligned with ESPR requirements.
My final thoughts..
We're moving in a world where governments are cracking down on systemic issues caused by big industry. Where consumers... especially the new generation... are demanding more fairness, more transparency, more balance. And so they should!
The Digital Product Passport isn't some bureaucratic exercise dreamed up in Brussels to make life difficult for manufacturers. It's a direct response to decades of environmental damage, exploitative supply chains and a complete lack of product transparency that consumers, regulators and responsible businesses are no longer willing to tolerate.
This isn't just a new regulation. It's a new way of society operating in a fairer, more transparent, more equal way.
So the question isn't whether you have to comply... it's whether you can afford not to.
At Circuland, we're building the tools to make DPP compliance straightforward, scalable and genuinely useful... not just a tick-box exercise. If you're a UK manufacturer looking to get ahead of these regulations, get in touch. The clock is already ticking.