yellow3 / Digital Product Passport

Buyer resource

Digital Product Passport procurement

Buying Digital Product Passport capability is not buying a QR code: the responsibility stays with you, so the procurement must decide what to buy, what you have, and what must stay portable.

What this helps you do
Run the purchase in five stages and put the terms that protect the economic operator into the contract.
Evidence basis
The yellow3 Buyer Platform method, Implementing Regulation (EU) 2026/1778, Regulation (EU) 2024/1781.
Updated
Regulatory status checked 28 September 2026

The method

Five stages, in order

1. Strategy
Scope, outcomes and obligations. Define the business outcome, regulatory scope and non-negotiable principles before making technology decisions.
2. Readiness
Systems, data and ownership. Assess systems, product data, supplier evidence and governance. Every gap becomes owned work with a deadline.
3. Capability architecture
Define what must be bought. Decide which capabilities must be bought, which already exist internally, and which must stay portable.
4. Evidence-based selection
Compare suppliers without scores. Evaluate providers against the programme's own capability requirements. Review evidence and unresolved questions before deciding.
5. Structured procurement
Responses, terms and conditions. Ask providers under evaluation for evidence, and record their responses separately from independent findings.

Terms that protect the economic operator

These are contract terms a buyer chooses to require. Each rests on a legal fact, named alongside it.

Operator of record. The contract states that you remain responsible for registration and accuracy, and describes what the provider does on your behalf. The law keeps the responsibility with you even where a provider does the work (Implementing Regulation (EU) 2026/1778, Article 19(4)).

An exit you can use. A sample export readable without the provider's tools, and a right to leave if the provider does not meet the ESPR Article 11(3) service-provider requirements once that delegated act is adopted. The act is not yet adopted (status checked 28 September 2026), which argues for a short first term.

An independent backup. ESPR Article 10(4) requires a back-up copy with an independent Digital Product Passport service provider, so a backup held by the same provider does not satisfy it.

Compare on evidence, not on scores

At selection, compare providers against your own requirements, and record each provider's statements separately from what you or an independent source can verify. The ten questions in how to choose a provider are a starting set; the software comparison shows what each provider states publicly today. The yellow3 Buyer Platform runs the five stages as a governed programme with a decision record.

Sources and status

Legal statements cite the article that imposes them, and every date carries its legal status, as in the Digital Product Passport 2026 executive report. Regulatory status checked 28 September 2026; yellow3 re-checks the Official Journal and CEN-CENELEC's published standards every week. This page separates what the law requires from what a buyer may choose to require, and neither is legal advice.