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Step 3

Supply-chain data collection

Most DPP programmes stall not because of the technology but because supply-chain data is incomplete or inconsistent. A disciplined approach is the single biggest predictor of on-time compliance.

Principle: federate, don't centralise

The DPP is a federated record. Each supply-chain tier holds the data it owns; your DPP resolves to it with a signed pointer. Do not ask suppliers to hand over raw data you do not need — ask them to expose a verifiable attestation for the fields you are required to publish.

Collection pattern

  1. Map data ownership. For each required field, identify the tier that holds the authoritative source — raw-material producer, component supplier, contract manufacturer, distributor.
  2. Align on format. Adopt a reference data model (CIRPASS + sector extension). Avoid bespoke spreadsheets that cannot be machine-validated.
  3. Contract for access. Add a DPP data clause to supplier agreements. Cover confidentiality, refresh cadence, and escalation when data is missing.
  4. Automate exchange. Prefer API or Verifiable Credential exchange over manual forms. One-time CSV drops create version drift.
  5. Validate on ingest. Reject incomplete or inconsistent submissions at the boundary. Do not let bad data enter your DPP pipeline.

Template clauses

Data clause (supplier agreement). The Supplier shall provide, for each unit or batch delivered, the data points listed in Annex X in the format specified in Annex Y, within the timelines set out therein. Data shall be accompanied by a signed attestation in the form of a W3C Verifiable Credential or an equivalent tamper-evident signature.

Confidentiality carve-out. Data reasonably identified as confidential business information (e.g., exact formulations, supplier identities upstream of the Supplier) shall not appear in the public layer of the Purchaser's Digital Product Passport and shall be shared only under the restricted-layer access rules.

These are starting clauses, not legal advice. Adapt with counsel.

Common failure modes

  • Asking for data you do not need, then struggling with its confidentiality.
  • Centralising supplier data into a single DB instead of resolving to signed sources.
  • Relying on annual CSV refreshes — the DPP is expected to reflect in-life updates (recalls, part swaps).
  • Ignoring tier-3+ where recycled-content and carbon data actually originate.