Preparing for Digital Product Passports: Your FMD Readiness Checklist

The Digital Product Passport (DPP) is no longer a “someday” idea.

It’s happening now — and it's happening fast.

Driven by the European Union’s Circular Economy Action Plan and new Ecodesign regulations, the DPP will change how product data is managed, shared, and regulated across the entire supply chain.

And at the core of it?

You guessed it:

Full Material Disclosure (FMD).

What is a Digital Product Passport (DPP), Really?

Think of the DPP as a digital ID for products — kind of like a passport, but instead of stamps, it holds data about:

What the product is made of

How it was manufactured

Whether it contains hazardous substances

How to recycle, reuse, or safely dispose of it

And — soon — its carbon footprint

This passport will live in a standardized digital format, accessible via a QR code or NFC tag on the product.

The goal? To support transparency, sustainability, and a true circular economy.

What Does That Mean for You?

If you manufacture or supply products in the EU, you’ll be expected to:

• Share detailed material composition data (FMD)
• Report regulated substances (e.g., REACH SVHCs, RoHS, POPs)
• Identify and validate recyclability information
• Provide data digitally — not in PDFs, but machine-readable formats like XML

And if you’re not ready?

You could face delays, rejected shipments, or loss of market access.

Your FMD Readiness Checklist for DPP Compliance

Here’s a straightforward list to assess where you stand — and what you need to do next.

Do you have Full Material Disclosure for your products?

• Homogeneous-level breakdown?
• CAS numbers for each substance?
• Weight, concentration, or PPM values? If not, start with high-volume or EU-market parts.

Are you tracking regulated substances (REACH, RoHS, Prop 65, etc.)?

• SVHCs (Substances of Very High Concern) updated every 6 months?
• RoHS exemptions validated and documented?
• POPs or TSCA checks done where applicable?

Do you collect and validate supporting documentation?

• Certificates of Compliance (CoC) or DoC?
• Safety Data Sheets (SDS)?
• 3rd-party lab reports (SGS, Intertek)?
• Evidence for any claimed exemptions?

Is your FMD data system-readable and exportable?

• Using standards like IPC 1752A, IEC 62474?
• Able to generate XML or other DPP-ready formats?
• Avoiding static PDFs or Excel files as your “final source”?

Are your suppliers trained and ready?

• Do they know how to provide FMDs?
• Are you supporting them with templates/tools?
• Is FMD part of your procurement onboarding?

Do you have a plan for ongoing FMD maintenance?

• Annual or semi-annual updates to catch new SVHCs?
• A version control system in place?
• Triggered updates when part specs change?

Are you collecting circularity and recyclability data?

• Can your team identify which materials are recyclable?
• Are hazardous substances labeled to guide safe disposal?
• Are you flagging parts that hinder reuse or material recovery?

Don’t Wait — DPPs Are Already Rolling Out

The EU’s Battery Regulation already mandates DPPs.

Textiles, electronics, construction, and furniture are next.

DPP won’t be optional — and the only way to do it right is to start with reliable FMD.

Final Word:

DPP isn’t just a regulatory requirement.

It’s a business opportunity to stand out as a transparent, sustainable, and future-ready brand.

Start by cleaning up your FMD game.

Build the digital backbone.

And get ahead — while your competitors scramble to catch up.

Need help getting your FMDs DPP-ready?

Acquis Compliance Tool was built for exactly this — validate, structure, and export your data in industry-compliant XML.

Book a demo here to see the tool in action