I Supply Multiple Value Chains: How Do I Manage Different DPP Requirements for Each Customer?
Persona: Commercial Director, industrial semi-finished products manufacturer, Europe
The short answer: you cannot satisfy all customers with a single format. But you can use the same product data foundation to generate different outputs, tailored to each customer’s requirements. Your material — whether rolled steel, polymer compound, or technical fibre — enters industries governed by completely different ESPR delegated acts.
The ESPR framework does not only apply to manufacturers of finished goods: the delegated acts currently under development may also cover intermediate products and upstream materials in many cases. You will have your own DPP, defined by the delegated act applicable to your product category. But your customers will have different DPPs, each designed around the requirements of their own sector.
A customer in the construction sector must comply with the Construction Products Regulation, which establishes specific environmental and information requirements depending on the product category. A customer in automotive or electronics will have information requirements defined by its own ESPR delegated act. A customer producing packaging will need to declare the percentage of post-consumer recycled content, according to the PPWR.
Same material. Same supplier. Three completely different data requirements.
The Challenge Is Not Your DPP — It Is the Multiplicity of DPPs Across the Value Chain
Every customer building its own DPP will need your product data.
Carbon footprint calculated according to the methodology required by their delegated act, batch-level certified recycled content, process traceability, substances of concern above defined thresholds: these data points cannot be created at the moment they are requested.
They either already exist — structured, updateable, and linked to the specific batch — or you become the compliance bottleneck for your customer. In most cases, the problem is not that the data does not exist. It does exist, somewhere.
The issue is that it moves through the supply chain in unstructured formats: certificates of analysis in PDF files, invoice records, archived emails. Reconstructing the chain takes weeks. When a customer is facing a regulatory deadline, those weeks simply do not exist.
One Set of Data, Multiple Outputs for Different Value Chains
The solution is not to create a different document for every customer. The solution is to build a data architecture that allows the same structured product information to generate the output required by each delegated act. Not a separate DPP for every customer, but a structured data system capable of adapting outputs to the specific DPP requirements of each value chain.
Companies that build this infrastructure stop being viewed simply as commodity suppliers and become compliance partners. The reverse side of this opportunity is equally tangible.
A buyer under regulatory pressure will turn to its established supplier to obtain the data needed for its DPP. If those data are not structured — or cannot be found at all — the buyer cannot wait.
There is a deadline. They look for an alternative. They find a supplier that is already prepared and can deliver on time. They rarely come back. The relationship with the new supplier was established at the most critical moment: when the traditional supplier was unable to respond. The structured supplier wins the immediate order and strengthens the customer relationship over the medium term. Not because it competed on price or product quality — but because it was the only supplier able to provide what was needed when it mattered.
The question is not whether companies should structure their product data for the DPP value chain. The question is how much time remains before one of their customers has already chosen someone else.
Those who prepare in advance gain more than a compliance advantage: they build customer loyalty by becoming the supplier competitors with unstructured data were unable to be when it mattered most.
