Transparency Obligations: The New Rules for Supply Chain Disclosure
Under the ESPR, "trust but verify" has been replaced by a legal mandate for audited disclosure. Article 24 introduces a strict reporting regime for all large enterprises regarding their unsold products, while the DPP mandates that product claims be backed by machine-readable data. This is the end of vague "green" marketing.
The rationale is to create a level playing field. By standardizing how sustainability is reported, the EU ensures that companies investing in genuine circularity are not undercut by "greenwashers".
The Three Layers of Mandatory Data
The regulation envisions a tiered access model for product information:
The Public Layer: Accessible to any consumer via QR code; includes general sustainability metrics and repair instructions.
The Restricted Layer: Accessible to professional repairers and recyclers; includes detailed technical schematics and material locations.
The Confidential Layer: Reserved for market surveillance authorities; includes full conformity documentation and due diligence audit records.
Pro-Tip: 99% Uptime is the Standard
Recent Commission consultations for DPP service providers emphasize that digital data must be available at all times. A 99% uptime requirement is expected, as manufacturing lines will need to upload data in real-time to avoid stopping production.
Strategic Advice: How to Prepare
Appoint a "Digital Compliance Officer": You need a dedicated lead to bridge the gap between sustainability (the data) and IT (the delivery).
Harmonize Your Data Standards: Ensure your data follows the GS1 Digital Link standard. This ensures your DPP is interoperable and future-proof against technological shifts.
Prepare for 2026 Disclosure: Large firms must collect discard data for 2025. Ensure your warehouse management systems are already tracking "reason for disposal".
To review your disclosure and reporting frameworks, email info@dpp-link.com