Digital Product Passports beyond Europe: how global markets are converging toward product data requirements

When discussing Digital Product Passports (DPPs), most attention naturally focuses on Europe. The European Union’s Ecodesign for Sustainable Products Regulation (ESPR) has established the most comprehensive framework for product-level data and is expected to make DPPs a market-access requirement for a growing number of product categories, including batteries, textiles, electronics, furniture, and construction products.

However, Digital Product Passports are not limited to the European regulatory landscape. Around the world, governments and industries are progressively converging toward similar principles centered on product-level data, traceability, interoperability, and verifiable supply chain information.

Several countries are already introducing DPP-related initiatives, often starting with specific sectors, materials, or strategic supply chains. Examples include Vietnam’s Law on Products and Goods Quality and the Digital Product Passport requirements for construction steel products in the United Arab Emirates. Other jurisdictions are pursuing sector-specific initiatives in areas such as batteries, textiles, food traceability, and customs modernization.

For exporters and non-EU manufacturers, these developments are becoming increasingly strategic. Alignment with European and international traceability standards is progressively turning into a prerequisite for maintaining access to global value chains and regulated markets.

Vietnam: the most advanced non-EU Digital Product Passport Regulation

Among all jurisdictions outside Europe, Vietnam currently represents the clearest example of a legally binding Digital Product Passport framework.

In June 2024, Vietnam adopted amendments to its Law on Products and Goods Quality, introducing explicit references to Digital Product Passports and strengthening digital traceability requirements. The legislation entered into force on January 1, 2026, and is supported by implementing measures that define obligations for manufacturers, importers, and traders.

The law introduces a risk-based classification system dividing products into low-, medium-, and high-risk categories. High-risk products will be subject to enhanced digital traceability obligations through a national platform using digital identifiers such as QR codes and barcodes.

The framework applies not only to domestic manufacturers but also to imported products, making it particularly relevant for European and international exporters operating in the Vietnamese market.

Vietnam’s approach is noteworthy because it moves beyond pilot programs and industry guidance, creating a legally enforceable foundation for DPP-style product information management.

United Arab Emirates: mandatory Digital Product Passports for construction steel

The United Arab Emirates has become one of the first jurisdictions outside Europe to implement a mandatory Digital Product Passport requirement for a specific industrial sector.

Through regulatory measures linked to construction product compliance, steel products used in construction projects must now be accompanied by digital product information accessible through a product passport system.

The objective is to improve transparency, quality assurance, sustainability reporting, and product traceability throughout the construction value chain.

While the scope remains limited to steel products, the UAE demonstrates an important trend increasingly observed worldwide: governments are introducing passport requirements sector by sector rather than through a single horizontal regulation.

For manufacturers exporting steel products into the UAE market, compliance with these digital information requirements is becoming a condition of market access.

China: From Traceability Infrastructure to Operational Battery Passports

China has not introduced a horizontal Digital Product Passport regulation covering all product categories. However, it is rapidly advancing in sector-specific traceability systems, particularly in batteries.

Most notably, China has launched a national battery traceability and digital identification system for new energy vehicle (NEV) batteries. The Interim Measures for the Management of Recycling and Comprehensive Utilization of Waste NEV Power Batteries entered into force on 1 April 2026, mandating full lifecycle traceability and the assignment of unique digital identities to each battery. The national platform officially became operational at the same time, requiring data reporting across production, vehicle integration, usage, and end-of-life recycling.

The system functions in practice as a battery passport-style framework, enabling end-to-end tracking of batteries across the entire value chain.

China’s approach differs from the European model. While the EU Battery Passport is primarily driven by sustainability, circular economy, and carbon footprint objectives, China’s framework emphasizes industrial supervision, recycling control, product safety, and lifecycle governance. However, both systems rely on similar building blocks, including unique identifiers, standardized data structures, and full lifecycle traceability.

Beyond batteries, China continues to expand traceability infrastructure across sectors including food, agriculture, electronics, and strategic industrial supply chains. For international companies, structured and machine-readable product data is increasingly becoming a prerequisite for operating within Chinese ecosystems as well as for exporting globally.

Turkey: regulatory alignment driven by trade and industrial integration

Turkey has not yet adopted a comprehensive Digital Product Passport regulation comparable to the EU’s ESPR. Nevertheless, the country is progressively integrating DPP-related concepts into various regulatory initiatives.

Much of this evolution is driven by Turkey’s close economic integration with Europe and the need to maintain alignment with emerging EU product requirements.

DPP-related provisions are beginning to appear in sectors such as batteries, construction products, ecodesign, and market surveillance. Rather than implementing a single national passport framework, Turkish authorities are pursuing a sector-by-sector approach that mirrors developments within the European Union.

For companies exporting into Turkey or sourcing products from Turkish suppliers, monitoring future regulatory developments will be increasingly important.

Japan: battery passport programs accelerate

Japan is emerging as one of the most active countries in the development of battery passport ecosystems.

The Ministry of Economy, Trade and Industry (METI) has launched dedicated programs to support the development and demonstration of battery passport infrastructure, particularly for electric vehicle batteries and energy storage systems.

Although no mandatory nationwide DPP regulation currently exists, government-supported initiatives are helping establish the technical and governance foundations necessary for future implementation.

Japan’s efforts are largely motivated by the need to maintain international competitiveness and ensure compatibility with global battery supply chain requirements, including those emerging from Europe.

South Korea: preparing through pilot projects

South Korea is following a similar trajectory, with multiple industry-led and government-supported pilot projects focused on battery passports and supply chain transparency.

These initiatives are designed to help Korean manufacturers prepare for international regulatory requirements while strengthening domestic capabilities in digital traceability technologies.

South Korea’s investments in pilot programs demonstrate growing recognition that digital product information will become an essential component of future industrial competitiveness.

United States: from traceability regulation toward DPP principles

The United States does not currently have a federal Digital Product Passport regulation equivalent to the European ESPR. However, several regulatory initiatives are creating frameworks that share many of the same underlying characteristics.

The most advanced example is the Food Safety Modernization Act (FSMA) Section 204 Food Traceability Rule. This regulation requires companies handling designated high-risk foods to maintain standardized digital records documenting key supply chain events and traceability data.

Although the FDA does not use the term “Digital Product Passport,” the architecture strongly resembles DPP systems. Products receive unique identifiers, lifecycle events are recorded, standardized data must be maintained, and information must be made available to regulators when requested.

In parallel, U.S. Customs and Border Protection (CBP) is modernizing customs and trade compliance systems through initiatives such as the 21st Century Customs Framework. These efforts seek to improve product-level visibility, origin verification, forced-labor enforcement, and supply chain transparency.

As a result, many experts increasingly view the United States as a “DPP-adjacent” jurisdiction. The country is not implementing product passports through sustainability legislation, but it is building many of the same technical foundations through food safety, trade compliance, and customs enforcement.

For a truly exhaustive global assessment, companies should also monitor U.S. Environmental Protection Agency (EPA) battery traceability initiatives, Department of Energy battery passport programs, and supply chain transparency requirements linked to CBP and the Uyghur Forced Labor Prevention Act (UFLPA). These developments could move the United States from a DPP-adjacent framework toward genuine passport-style requirements over the next two to four years.

Australia, Canada and the United Kingdom: preparing for the future

Several other advanced economies are actively preparing for the rise of Digital Product Passports, even though mandatory regulations have not yet emerged.

In Australia, industry organizations and standards bodies are helping businesses prepare for DPP implementation, particularly in the textile and apparel sectors.

Canada is investing in digital credentials, trusted data infrastructure, and supply chain transparency initiatives that may ultimately support future passport systems.

Meanwhile, the United Kingdom is closely monitoring European developments and focusing on helping exporters comply with EU requirements while exploring its own approaches to product sustainability information.

These countries illustrate a broader trend: even where legislation is not yet mandatory, companies are already investing in the systems and data architectures required for future compliance.

The global expansion of product data requirements

A clear pattern is emerging across jurisdictions. While regulatory approaches differ, governments are increasingly converging around common principles:

·      Product-level traceability

·      Digital identification systems

·      Machine-readable data exchange

·      Supply chain transparency

·      Interoperability standards

·      Verifiable sustainability and compliance information

Many jurisdictions are beginning with strategic sectors such as batteries, construction materials, food products, textiles, and electronics. These industries combine high regulatory interest with complex international supply chains, making them natural candidates for early implementation.

At the same time, global standards organizations and industry groups are promoting common approaches to identifiers, data models, QR codes, RFID technologies, and interoperability frameworks. This standardization effort is accelerating the international diffusion of DPP concepts far beyond Europe.

Conclusion

Focusing only on European regulation therefore misses a broader transformation affecting international trade and industrial ecosystems. Product data is increasingly becoming part of the conditions required for products to circulate across markets.

While the European Union remains the primary regulatory driver, countries around the world are developing their own approaches to traceability, digital identification, and product information management. Some, such as Vietnam, China, and the United Arab Emirates, have already introduced legally binding passport-style requirements. Others, including Turkey, Japan, South Korea, and the United States, are building sector-specific frameworks that increasingly resemble Digital Product Passport systems.

For manufacturers, exporters, and supply chain operators, the strategic question is no longer whether Digital Product Passports will influence international trade. The question is how quickly organizations can build the data infrastructure, governance processes, and interoperability capabilities required to operate in a world where transparent product information becomes a standard expectation across multiple markets. 

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Frequently Asked Questions

Are Digital Product Passports only a European requirement?

No. While the EU’s ESPR is the most advanced and comprehensive framework, many countries are developing similar systems. These include binding regulations (e.g. Vietnam), sector-specific mandates (e.g. UAE steel, China Batteries), and traceability-driven frameworks (e.g. the United States).

Which countries outside Europe already have mandatory DPP-style regulations?

As of now, the clearest examples are:

🇻🇳 Vietnam: legally binding digital traceability and DPP references in product quality law (entering into force in 2026)

🇦🇪 United Arab Emirates: mandatory digital product passport requirements for selected steel construction products

🇨🇳 China: a mandatory national battery traceability system is now operational as of 1 April 2026, under MIIT’s Interim Measures for the management of recycling and utilisation of new energy vehicle batteries.

Most other countries are still in pilot or regulatory development phases.

Is the United States implementing Digital Product Passports?

Not directly. The U.S. does not have a horizontal DPP regulation. However, several frameworks strongly resemble DPP systems, especially:

• FDA FSMA Section 204 Food Traceability Rule

• Customs and supply-chain transparency initiatives (CBP modernization)

• Forced-labor and origin verification requirements (e.g. UFLPA enforcement)

Together, these are often considered “DPP-adjacent” developments.

What is FSMA Section 204 and why is it relevant?

FSMA Section 204 is a U.S. Food and Drug Administration rule requiring enhanced traceability for certain high-risk food products. It mandates standardized digital records of supply-chain events, enabling faster identification and recall of contaminated food.

Although not called a DPP, its structure mirrors key passport principles such as product identifiers, lifecycle events, and machine-readable data exchange.

Are Digital Product Passport requirements the same across countries?

No. Approaches vary significantly:

The EU focuses on sustainability and circular economy objectives

The U.S. prioritizes food safety and customs enforcement

China emphasizes industrial control and traceability standards

Vietnam and the UAE are introducing more direct regulatory obligations

Despite differences, all systems are converging toward structured, digital product-level data.

Which industries are most affected globally?

The most frequently targeted sectors include:

• Batteries (especially EV and energy storage)

• Textiles and apparel

• Electronics

• Construction materials (notably steel and cement)

• Food and agricultural products

These sectors combine regulatory sensitivity with complex global supply chains.

Are these requirements already affecting exporters?

Yes. Even when regulations are not fully implemented, exporters are increasingly required to provide structured product data, including origin, composition, and supply-chain documentation. This is especially true for companies exporting into the EU, U.S., and certain Asian markets.

Is this trend expected to expand further?

Yes. Most current initiatives suggest a gradual global convergence toward interoperable product data systems. Over time, more countries are expected to formalize sectoral or horizontal requirements, particularly in response to trade, sustainability, and supply-chain transparency pressures.