Over the past few months, we’ve been deep in the weeds on Digital Product Passports (DPPs). What started as a slow burn is now roaring toward centre stage, and whether you realise it or not, this is about to upend how compliance is done in almost every market.
This isn’t just about another layer of red tape. It’s a fundamental shift in how the entire value chain will be policed, verified, and held to account.
And if you’re still kicking the can down the road, outsourcing responsibility to suppliers or winging it with half-baked documents, let me be brutally honest: you’re not going to survive what’s coming next.
Let’s Talk About the Power Combo: DPPs + AI Enforcement
Here’s where things get spicy.
On the one hand, we’ve got Digital Product Passports: live, accessible records of everything a product is, claims to be, and must comply with.
On the other hand, we’ve got artificial intelligence already being deployed at port authorities and customs. AI tools will read packaging, check documentation against regulatory databases, and flag non-compliant goods faster than any human ever could.
Put these two together and you’ve essentially got:
- Real-time visibility into product data across supply chains
- Always-on, always-learning digital watchdogs that don’t sleep, bribe, or blink
- Instant enforcement opportunities, before your product even hits the shelf
This is compliance at machine scale.
Ten enforcement officers become a hundred. A hundred becomes a thousand. And none of them need a coffee break.
If you’re a founder-led brand in a regulated market, whether you make vapes, cosmetics, toys, electronics, or medical devices, you need to understand what this means.
The Days of “Plausible Deniability” Are Over
For years, many brands have built successful empires by skating the line. Relying on suppliers to “take care of compliance.” Avoiding difficult documentation. Hoping enforcement would be too slow or too sparse to catch up.
Those days are done.
In a world of Digital Product Passports and AI-enabled enforcement, your documentation isn’t tucked away in a dusty binder or siloed in your email inbox, it’s exposed, traceable, and publicly accountable.
- Where are your test reports?
- Can you show conformity with EU regulations, not just in theory, but in practice?
- Do your claims match your evidence?
If not, enforcement bodies won’t need to send an officer. A script will scan your data and trigger a flag.
And it won’t just be regulators paying attention. Major marketplaces, logistics providers, and retail partners are already planning to plug into these systems. If you think Amazon’s current documentation requirements are strict, wait until their compliance team is powered by AI with a direct feed into your DPP.
This isn’t the distant future. It’s beginning now.
What Actually Is a Digital Product Passport?
At its core, a Digital Product Passport is an online record tied to a physical product. It contains information about:
- Regulatory compliance and conformity
- Ingredients or materials used
- Environmental impact and sustainability
- Packaging details and recyclability
- Repairability, durability, and more
The exact scope will differ by product category; cosmetics will have different requirements than electronics or PPE, but the concept and end-game is the same.
DPPs are part of the broader EU Green Deal and Circular Economy Action Plan, which aim to make products safer, greener, and more transparent.
In practice, this means every product sold in the EU (and eventually beyond) will need a passport that travels with it, from factory to consumer to disposal.
That’s a monumental shift.
Compliance Moves Upstream: From Shelf to Supply Chain
Traditionally, compliance checks happened after products hit the market, usually after a complaint, audit, or random sampling. It was reactive, slow, and often ineffective.
With DPPs and AI, the model flips:
- Enforcement happens before products are listed
- Problems are flagged at the point of import
- Whole batches can be blocked, blacklisted, or removed from sale, automatically
This isn’t theoretical.
We’ve already seen cases in the vape industry where border authorities used AI to identify non-compliant devices based on visual and labelling cues. Customs officials in Germany, the Netherlands, and Spain are quietly using machine learning to prioritise inspections and stop goods that don’t meet specifications.
Now imagine giving those systems access to full product passports.
Your ingredients list, SDS, CE declaration, packaging specs, and lab tests, all laid bare. No margin for error. No more excuses.
What This Means for Founders
If you’re a founder, brand owner, or product entrepreneur, here’s the hard truth:
You are now the accountable person, whether you like it or not.
It’s no longer enough to pass the buck to your supplier in Shenzhen or your testing house in Poland. You need to know, with confidence:
- That your documents are valid, current, and real
- That your claims can be backed up, down to the packaging ink and battery cell
- That your supply chain partners are singing from the same hymn sheet
And you need a way to prove it, instantly.
That’s the role Digital Product Passports are going to play. They’re not just a regulatory burden. They’re a compliance timestamp, a proof of integrity, and if you do it right, a competitive advantage.
This Is Not Just a Threat: It’s an Opportunity
Let’s flip the script.
Yes, DPPs raise the bar. But they also level the playing field.
If you’ve been doing the right thing, investing in safety, testing, ethical sourcing, and sustainable packaging, you’ve probably been losing out to cheaper, dodgier competitors.
That’s about to change.
Because in a world where everyone’s documentation is visible and verified, the shortcuts get exposed. The cowboys get cut off. And the brands that have done the work finally get the recognition (and market access) they deserve.
That’s huge.
And it’s why we’ve spent the last year building our MAVRYX platform to align with these changes, creating living, breathing digital passports for the products we help bring to market. Not because it’s trendy. Because it’s necessary.
Five Things You Should Be Doing Right Now
Here’s how to get ahead before DPPs become mandatory across your sector:
- Map your compliance ecosystem
Identify all the documents, tests, and certifications you should have, not just what you think you have. Many brands are missing 30–50% of required paperwork. - Digitise and centralise everything
Paper records and scattered PDFs aren’t going to cut it. You need a cloud-based system that’s structured, shareable, and searchable. - Validate your supply chain
Are your suppliers providing you with legit documents? Have you verified their declarations? Are their test labs accredited? - Align with the DPP framework
Even if your product category isn’t on the DPP mandate list yet, it’s coming. Start building your internal passport now — category by category. - Automate where possible
From lab test expiry reminders to SDS generation and packaging reviews, automate the grunt work so you can focus on strategy and growth.
Final Word: Don’t Wait for the Knock on the Door
The worst mistake you can make is thinking this will blow over. That there’ll be another grace period. That you’ve still got time.
You don’t.
Once DPPs and AI enforcement fully kick in, the dominoes will fall fast:
- Non-compliant products blocked at the border
- Online listings suspended
- Brands blacklisted from marketplaces
- Retailers dropping risky suppliers
You won’t get a warning letter. You’ll get a system-generated takedown and a massive hole in your revenue.
The only way to protect your business is to treat compliance like an asset, not an afterthought.
That’s what I’ve been banging the drum about since 2017. And now, finally, the industry is catching up.
Digital Product Passports aren’t just another requirement. They’re validation of the work we’ve been doing for years, helping founders build safer, better, and more sustainable brands.
So the question is:
Are you ready to step up?
Or will your product be the next one to vanish at customs?
If you need help in identifying your compliance gaps, take our free compliance assessment tool – the ARC Methodology scorecard. We’ll send you a bespoke 25+ page report highlighting your weaknessess and a roadmap for fixing them.
Lee Bryan
CEO & Founder, Arcus Compliance
Author, How Safe Is Your Vape?
