Will the DPP Force Companies to Disclose Trade Secrets and Suppliers?
This is the question every entrepreneur, manufacturer, and supply chain manager asks as soon as they realize the Digital Product Passport applies to them. And the answer is: no — but with an important clarification that is worth understanding, because it changes how companies should prepare for DPP compliance, sustainability transparency, and ESG reporting obligations.
The Regulation Has Already Answered: Differentiated Access by Design
The ESPR Regulation was not written by idealists unaware of how markets work. European lawmakers fully understand that requiring companies to indiscriminately disclose suppliers, formulas, and production processes would be not only impractical, but counterproductive — no company would support a Digital Product Passport system that destroys its competitive advantage.
For this reason, the DPP has been designed with a differentiated access architecture: not everyone sees the same product information or sustainability data. The Regulation explicitly states that the passport must be accessible “based on the respective access rights defined in the applicable Delegated Act.”
In practice: the consumer sees one layer of product transparency information, the repairer sees more, the recycler sees what is needed for their operations, and market surveillance authorities access what is necessary for compliance checks. Commercially sensitive information — detailed compositions, specific supplier names, proprietary manufacturing processes — can remain restricted to actors with a legitimate right to access it.
The Batteries Regulation, which represents the first fully operational Digital Product Passport framework (DPP) and therefore the most concrete example of how the system will work, defines this explicitly: it establishes three levels of access — public information, information for parties with a legitimate interest, and information for authorities and notified bodies. This is not an optional design choice: it is a legal requirement embedded in the European regulatory framework.
What Is Actually Shared — and with Whom
The key conceptual distinction to keep in mind is between attribute and formula. A chemical company does not have to disclose its proprietary recipe, intellectual property, or confidential manufacturing process: it must declare the carbon footprint of the product, the percentage of substances of concern, and its recyclability. The sustainability attribute is shared; the process that generates it remains protected.
The same principle applies to an apparel manufacturer, textile producer, or industrial supplier: it does not necessarily have to disclose the name of its production facility to the end consumer — but it may need to share information about fibre origin or production conditions with market authorities or B2B customers with specific due diligence requirements.
This means the right question is not “do I have to reveal my secrets?” but rather:
“which information must I make available, to whom, and in what format?”
The answer will depend on the specific Delegated Act for each sector — which is why monitoring the evolution of these European sustainability regulations, DPP standards, and traceability requirements is strategically important, not just a compliance exercise.
The Paradox of Confidentiality
There is, however, a point that many overlook, and it is worth addressing honestly. The DPP does not require companies to disclose trade secrets, but it does require them to declare verifiable sustainability attributes. And verification, by definition, requires that someone — a third party, an authority, or a technical system — can check that those declarations correspond to reality.
This does not mean full transparency or unrestricted public disclosure. But it does mean that declaring without being able to prove is no longer sufficient.
Companies that today manage their supply chains opaquely — not out of bad faith, but simply because they have never needed to map suppliers beyond the first tier — will need to build that internal supply chain transparency before even deciding what to make public.
In other words: the DPP does not expose your secrets to the market. But it forces you to know them first.
The DPP is not an open window onto your suppliers: it is a mirror held up to your supply chain, product traceability system, and sustainability data infrastructure. What others see depends on how the system is designed. What you must see first is yourself.
