Every Digital Product Passport is, underneath, a structured dataset: 91 mandatory fields for an EU battery passport, 166 for an electronics DPP under ESPR + EPREL. The regulation tells you which fields. It does not tell you how to fill them — and that is the entire decision. The market splits into two answers: hire a compliance consultancy to assemble the data as a project, or run an automated pipeline that reads the documents you already have. They differ not in marketing but in mechanics, cost shape, and who owns the passport after launch.
The two models, in one sentence each
Consulting-heavy: a firm runs a discovery project — workshops, spreadsheets, supplier emails — and hands back a completed passport (and an invoice) at the end. Agent-first: a platform ingests your existing documents (datasheets, EPREL entries, test reports, SVHC declarations), maps each value to its regulated field automatically, and requests only what's genuinely missing from suppliers. The first sells you labour; the second sells you a repeatable process you keep.
Where the fields actually come from
This is the part both models have to solve, and it's worth being concrete. Take the EU battery passport's 91 fields. Most are not new information you must invent — they are values that already exist in documents you hold or can request:
- Cell chemistry, capacity, voltage, internal resistance → the cell supplier's datasheet
- Carbon footprint per kWh → your PEF study (Product Environmental Footprint)
- Critical raw materials (lithium, cobalt, nickel, natural graphite) → supply-chain due-diligence records
- CE marking, conformity assessment body → your Declaration of Conformity and test reports
- Recycled content, collection and recycling info → your own production and end-of-life data
A consulting project gathers these by hand: someone reads each PDF, types the value into a spreadsheet, chases the supplier for the gaps, and repeats it per product. An automated pipeline reads the same PDFs, extracts the values, and writes them straight into the mapped fields — leaving only the genuinely-missing ones to request. The data source is identical. What differs is whether a person retypes it once per product, or a process does it every time.
Why the field count matters more at 166 than at 91
An electronics DPP under ESPR carries roughly 166 fields, drawing on your EPREL registration, CE test reports, RoHS and WEEE data, and spec sheets. Whichever model you pick, the cost of the manual approach scales with field count × product count. A consultancy charging by the project quotes a battery passport (91 fields) lower than an electronics one (166) for the same reason a removals firm charges by the box: more units of manual work. The automated approach inverts that — once the 166-field template is mapped to your document types, the marginal cost of the next product is close to zero. The field count stops being a cost driver and becomes a one-time setup.
Who owns the passport after launch
A passport is not done at launch. The delegated acts under both the Battery Regulation and ESPR keep evolving; fields get added, methodologies change, and a passport must stay accurate for the life of the product. With a consulting project, the deliverable is a snapshot — when the rules shift, you commission another engagement. With a platform, template updates land in place and your existing passports flag the new empty fields for you to fill on your own schedule. The question to ask any provider is not 'can you produce a compliant passport?' but 'who maintains it in 2028, and what does that cost?'
When consulting is still the right call
This isn't an argument that consulting has no place. If you have a handful of complex products, no internal documents in order, and need the underlying PEF study or conformity assessment done from scratch, a consultancy does work software cannot: it produces the source data, not just the passport around it. The honest split is — consulting to create data that doesn't exist yet (a PEF study, a due-diligence audit); a platform to assemble, publish, and maintain data that does. Most manufacturers facing 2027 already hold most of their data; their bottleneck is assembly and upkeep, which is the part automation removes.
Frequently asked questions
Is a DPP platform cheaper than a compliance consultant?
For assembling and maintaining passports from data you already hold, yes — usually by a wide margin, because platform cost is a flat subscription while consulting scales with field count and product count. TracePass plans start at €49/month for manual entry and €350/month for AI-assisted extraction. Consulting is better value only when you need source data created from scratch (a PEF study, a conformity assessment), which a platform doesn't produce.
How many fields are in a Digital Product Passport?
It depends on the product category. An EU battery passport under Regulation 2023/1542 has 91 mandatory fields. An electronics DPP under ESPR + EPREL has roughly 166. Textiles, construction products, and other categories have their own field sets, defined by each product's delegated act.
Can software really fill the fields automatically?
For the fields whose values already exist in documents you hold — datasheets, EPREL registrations, test reports, SVHC declarations — yes: the platform extracts the value and writes it to the mapped field. Fields whose values genuinely don't exist yet (or live only with a supplier) can't be invented; the platform identifies those and requests them, rather than leaving you to discover the gaps manually.
Who is responsible if the passport data is wrong?
The economic operator placing the product on the EU market — manufacturer, importer, or authorised representative — is legally responsible for the passport's accuracy, regardless of whether a consultant or a platform helped assemble it. That's why ownership and maintenance after launch matter: you carry the liability for the life of the product.
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