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Step 2

Roadmap to compliance

A six-stage plan from scoping to live operations. Stage lengths are order-of-magnitude for a mid-size manufacturer with one product family in scope. SMEs and single-SKU lines can compress; multi-category portfolios will stretch.

  1. Scope your product portfolio

    Typical effort: 2–4 weeks

    Inventory product families against adopted and in-scoping delegated acts. Flag the earliest applies-from date per family. Decide whether you will publish a DPP per product model, per batch, or per individual unit.

    Deliverables

    • Product-family inventory with legal basis and deadlines
    • Policy on DPP granularity (model / batch / instance)

  2. Map your supply-chain data

    Typical effort: 1–3 months

    Identify every data point required by the applicable act. For each, identify the authoritative source (which tier of the supply chain, which system, which format). Expect gaps at tier-2 and beyond — this is where most programmes stall.

    Deliverables

    • Data-point catalogue with source, owner and format
    • Supplier questionnaire and NDA template

  3. Pick your data model and carrier

    Typical effort: 2–6 weeks

    Align on a data model (CIRPASS reference + sector extensions) and choose carriers per product (QR, Data Matrix, NFC, RFID). Battery regulation mandates QR; most other sectors are technology-neutral.

    Deliverables

    • Data-model decision record
    • Carrier policy per product family

  4. Build or buy the DPP service

    Typical effort: 3–9 months

    Either integrate with a DPP service provider or build on open-source components. Minimum capabilities: identifier registration, secure publication, layered access control, version history, durable URL resolution.

    Deliverables

    • Architecture decision record
    • Vendor contract or in-house service

  5. Register identifiers and publish

    Typical effort: 2–4 weeks

    Register GTINs, DIDs or sector-specific identifiers. Stand up the resolver. Publish initial DPPs for a pilot product line. Validate end-to-end scanning by consumer apps and authority tooling.

    Deliverables

    • Registered identifiers
    • Live pilot DPPs

  6. Operate and update

    Typical effort: Ongoing

    Keep DPP records accurate over the product lifetime. Propagate changes (recalls, repairs, ownership transfers) within the timelines set by the sector act. Archive retired passports per retention rules.

    Deliverables

    • Change-management SLA
    • Archive and retention policy