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DPP Sector Update June 2026: Steel, Batteries, and GS1 Pilots

JRC steel draft, battery mandate from February 2027, Driscoll's serialization project: what June 2026's DPP developments mean for manufacturers.

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DPP Sector Update June 2026: Steel, Batteries, and GS1 Pilots

Overview: A Packed Month for the Digital Product Passport

June 2026 brought several parallel developments in the Digital Product Passport space together: the JRC published a concrete data draft for steel products, Minespider released a comprehensive implementation report on the Battery Regulation, and Driscoll's demonstrated at GS1 Connect 2026 how serialization works in practice in food logistics. At the same time, the European Commission opened infringement proceedings against 20 member states for inadequate transposition of the EmpCo Directive. The signals are converging: the regulatory clock is ticking, and the gap between policy ambition and industrial reality remains substantial.

Steel: JRC Draft Defines Data Granularity and PCF Methodology

Lot-Level as Mandatory Architecture

The European Commission's Joint Research Centre (JRC) has published its draft DPP data requirements for iron and steel intermediate products. The draft systematically distinguishes between two levels of data granularity: lot level and item level. This distinction is not a technical footnote — it is an architectural decision with far-reaching consequences for ERP systems and data models.

Particularly relevant: under the JRC draft, the product-specific carbon footprint (PCF) is maintained at lot level and must be calculated using ISO 14067-compatible methods. This means steel manufacturers cannot simply report a generic company-level CO₂ figure — they must document and keep the PCF current for each individual lot.

What "Up-to-Date Information" Actually Means

ESPR Regulation (EU) 2024/1781 requires that the DPP contain "up-to-date and accurate information," without specifying an explicit update frequency. In the steel context, this means concretely: whenever a new lot is produced, a new or updated passport entry must be created. Organizations relying on static product data sheets are structurally unable to meet these requirements.

In parallel, the European Commission has opened a public consultation on ecodesign requirements for steel, addressing circularity, recycling rates, and low-emission steel. Stakeholders have until fall 2026 to submit feedback.

Batteries: Implementation Report Reveals Systemic Gaps

February 2027 Mandatory Date Is Approaching

Minespider has published its "Digital Battery Passport Implementation Report 2026" — one of the most comprehensive industry analyses to date on the state of implementation of the Battery Regulation (EU) 2023/1542. The conclusion is sobering: data fragmentation and the absence of processes for dynamic data updates are the most frequently cited obstacles.

The Battery Regulation already implicitly recognizes the lot/item distinction: capacity data that changes through degradation must be kept current. A battery DPP is therefore not a one-time document but a living dataset that must be maintained throughout the entire product lifecycle — a requirement that is nearly impossible to fulfill without a clear system architecture.

Data Fragmentation as the Core Problem

The Minespider report identifies three structural weaknesses:

  1. Missing upstream data: Raw material suppliers provide sustainability data in inconsistent formats, or not at all.
  2. No API standardization: Different systems along the supply chain don't speak a common language.
  3. Unclear responsibilities: Who maintains the DPP after the first sale — the manufacturer, the importer, or the operator?

The mandatory date for the digital battery passport is February 18, 2027. For manufacturers who have not yet built a data pipeline, time is running short.

GS1 Pilots: Driscoll's Serializes One Billion Berry Clamshells

Item-Level Traceability in Practice

At GS1 Connect 2026, Driscoll's presented a project that impressively demonstrates the scalability of serialization approaches: the company has assigned unique identities to over one billion berry clamshells and is currently migrating to fully GS1 Digital Link-compliant QR codes. The project closes the feedback loop between consumer complaints and farm-level traceability — a requirement that applies analogously in regulated sectors such as steel or batteries.

Technically relevant: TEKLYNX has updated its CODESOFT software to support GS1 "++" encoding schemes, which allow web URLs to be written directly into RAIN RFID tag memory — a requirement arising from the combination of EN 18220 and the GS1 Digital Link standard. This shows that the toolchain for scalable serialization exists — but it must be deliberately deployed.

The CIRPASS-2 consortium, in its comments on the registry draft, recommended that the standard EN 18219 be included as a binding reference in the implementing regulation — in part to ensure interoperability with GS1 Digital Link. The registry itself stores only the unique identifier, the resolver endpoint, and the commodity code — not the actual passport data. The passport data resides with the manufacturer or an authorized data service.

A minimal example of a GS1 Digital Link-compliant URL, as it might appear in a QR code on product packaging:

https://id.example.com/01/04012345678901/10/LOT2026A/21/SN00042

The segments encode:

  • 01 → GTIN
  • 10 → Lot number
  • 21 → Serial number

This structure is machine-readable, resolver-compatible, and allows different DPP endpoints to be served on a per-lot basis.

Regulatory Environment: Greenwashing and the EmpCo Directive

The European Commission has initiated infringement proceedings against 20 member states for failing to fully transpose the Directive Empowering Consumers for the Green Transition (EU) 2024/825 into national law. The directive prohibits misleading environmental claims and requires manufacturers to clearly disclose information on durability and repairability.

The connection to the DPP is direct: if you report sustainability data in a DPP that is not methodologically substantiated, you risk not only compliance violations under ESPR but also greenwashing allegations under the EmpCo Directive. The requirement for "up-to-date and accurate information" in the DPP is therefore simultaneously a requirement for data quality and verifiability.

Ecommerce Europe has called in a position paper for the European Commission to maintain flexible data granularity and enable a phased rollout. The group emphasizes that existing business processes must serve as the starting point — a plea for pragmatism that aptly describes the tensions inherent in implementation.

Conclusion: Make Architecture Decisions Now

The developments of June 2026 reveal a consistent pattern: regulatory requirements are becoming more concrete, technical standards are converging, and early pilots are proving feasibility. What is still missing is broad industrial adoption.

For manufacturers in regulated sectors — steel, batteries, textiles — this translates into three immediate areas of action:

  • Clarify data granularity: Will data be maintained at the product, lot, or serial-number level? This decision determines the entire backend architecture.
  • Build resolver infrastructure: The DPP registry stores only the pointer — the actual data must be served via a stable, publicly accessible endpoint.
  • Plan for dynamic updates: Static data sheets do not satisfy ESPR's currency requirement. If you are building a DPP system today, you must design update workflows in from the start.

February 2027 for batteries is the next hard deadline. The steel consultation runs until fall 2026. The time for conceptual discussion is over — implementation decisions are needed now.

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