If you still think the Digital Product Passport is a distant EU concept, look outside Europe
While the market has been micro-focusing on the EU’s timelines for the Ecodesign for Sustainable Products Regulation (ESPR), China just quietly turned theory into hard national law.
China’s Order No. 73 is officially live. It makes digital passports legally mandatory for every single EV battery on their market. No pilots, no voluntary phase-ins. If you manufacture, sell, repair, or scrap a battery in China, its entire lifecycle data now flows through a mandatory national platform. They aren't playing around with compliance either, reporting errors carry a fine of 50,000 Yuan (~€6,500) per “mistake”.
The real risk: Global regulatory lag
For years, the consensus was that Europe would dictate the rules of the game for circular data. But by moving first with strict, granular laws for the automotive sector, China is effectively setting the baseline for the global battery "digital thread".
The danger for global businesses is massive: if non-EU countries anchor the infrastructure and data architectures first, everyone else will be forced to play catch-up or manage completely separate, frustratingly incompatible compliance engines.
Meanwhile, the clock is ticking for European Textiles
This isn't just an automotive or battery problem. Right now, the EU is building momentum for consumer goods. This July 19, 2026, two major milestones hit simultaneously: the EU Central DPP Registry goes live, and a strict ban on large brands destroying unsold apparel and footwear officially kicks in.
While the formal Textile DPP rules are slated for final adoption in Q2 2027 (pushing the hard data-carrying mandate to 2028/2029 once transition windows close), the operational foundations are being laid out today.
The textile industry is notoriously fragmented. Waiting until the final acts are signed to figure out how to track fiber origins, chemical compliance, and supplier data from Tier 2 and Tier 3 factories is a losing strategy.
What leaders need to do now:
- Move from ESG to Operations: A DPP is a market-access requirement. If you cannot provide the data, you legally cannot sell the product. This is a core operational risk with huge impact.
- Don't wait for the final text: The precise technical requirements will evolve, but the core data foundations (composition, origin, repairability, and end-of-life routes) are already clear. Start mapping your supply chain data architecture now.
- Invest in Interoperability: Whether you deal in textiles, batteries, tires, construction materials or electronics, the technology stack you choose to manage your product's "digital identity" must be open and flexible enough to “talk” to an EU registry today and a Chinese national platform tomorrow.
The digital age of the circular economy isn't approaching anymore; the framework is built, and the first wave of laws is actively hitting the market.