DIGITAL PRODUCT PASSPORTS IN THE EU: REGULATORY ARCHITECTURE, STATISTICAL BOUNDARIES AND DIGITAL PREREQUISITES OF MANUFACTURING

Abstract

The Digital Product Passport is becoming an operational information infrastructure of the EU single market and requires firms to organise product identifiers, attributes, access rights and data exchange across the supply chain. The paper systematises the Digital Product Passport regulatory architecture, outlines statistically defensible matching boundaries for ESPR product groups and evaluates observable digital prerequisites of EU manufacturing. The analysis combines Regulation (EU) 2024/1781, the 2025–2030 ESPR Working Plan, the Batteries Regulation, Commission Implementing Regulation (EU) 2026/1778, harmonised Digital Product Passport standards and Eurostat 2025 ICT-use data. Sectoral NACE C indicators and enterprise-size indicators are treated as separate statistical dimensions. In manufacturing, ERP was used by 57.62% of enterprises, paid cloud services by 53.96%, BI by 16.87%, and 72% reached at least a basic level of digital intensity. Compared with the full population of surveyed EU enterprises, manufacturing exceeded the ERP benchmark by 11.17 percentage points, while the differences for paid cloud services and BI were only 1.22 and 0.59 points; basic DII was identical at 72%. Across the surveyed economy, large-small gaps were 57.79 points for BI, 50.98 for employee-performed data analytics, 47.63 for ERP, 35.37 for paid cloud services and 27.00 for basic DII. A worked example for batteries demonstrates why NACE/CPA/Prodcom positions cannot serve as direct legal identifiers of Digital Product Passport coverage. Digital Product Passport readiness is primarily a data-governance and interoperability capability rather than the presence of any single digital system. Manufacturing shows a relatively strong base of operational data integration without a general digital advantage across all indicators. Narrow and extended analytical matching boundaries allow statistical evidence to inform the economic assessment of Digital Product Passport transition without substituting statistical codes for the legal scope of product acts.