A widespread assumption about the European digital product passport is that companies will eventually upload product information to a central European system. That is not the architecture. The registry holds a unique identifier, the location of the passport and some metadata. The product data itself stays with the economic operator. Almost every practical consequence follows from that one design decision.
The architecture is decentralised by design. The central component records the unique identifier, where the passport can be found and a limited set of metadata. It is a directory, not a repository.
A central database would have made the passport a submission exercise: assemble a file, upload it, move on. A decentralised model makes it an availability commitment. The passport has to resolve, remain accurate and stay accessible for as long as the obligation lasts.
Attention has concentrated on sectoral delegated acts, and those timelines stretch across the second half of the decade. The first genuinely hard registration deadline is earlier: 18 February 2027, for certain large batteries.
That matters even to organisations with no battery product, because it is the first moment the architecture will be exercised in anger. What breaks there will shape what every subsequent sector is asked to do.
A passport describes a product that already exists. If provenance and composition were not captured when the product was made, they cannot be recovered afterwards by analysis or by assertion.
This is the single most expensive misunderstanding in the field. Companies plan to solve the passport when the delegated act for their sector lands, without recognising that the products in scope at that point are being manufactured now.
Of everything a passport is likely to require, recovered material content is the most difficult to substantiate, because it depends on a chain of custody that crosses organisational boundaries before the product is even designed.
A percentage of recycled content is not a property that can be measured in the finished item with any confidence. It is a claim that rests entirely on records held by other parties, which is precisely why it attracts enforcement attention.
A passport is only as useful as the identifier that resolves to it. Getting identification right, at the correct level of granularity, is unglamorous work that determines whether the system functions at all.
The recurring question is granularity: per item, per batch, per model. Choosing too fine a level creates an unmanageable data burden and choosing too coarse a level produces a passport that cannot answer the question it was created for.
REZET Hub was designed around this order of operations: capture provenance, custody, transformation and outcome as structured records at the moment the activity happens, so that whatever format the passport eventually demands can be produced from data that already exists.
Companies that wait for their sectoral act will spend that period producing products they cannot describe. Companies that capture provenance now will spend it mapping records they already hold onto a format that is still being written.
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