The Digital Product Passport (DPP) is emerging as a key instrument in the European Union's transition toward a transparent, traceable, and circular economy. Building on the regulatory frameworks of the Battery Regulation, the Ecodesign for Sustainable Products Regulation (ESPR), and the draft standards of the DIN EN 18216 - 18246 series, the DPP establishes a service-oriented digital infrastructure for standardized information exchange across product life cycles. Its implementation requires a complex ecosystem of interacting stakeholders, including Economic Operators (EO), Service Providers (SP), and downstream actors each governed by distinct access and modification rights. Within this ecosystem, the management of granular data interactions poses major technical and organizational challenges. A multi-layered architecture based on Role-Based Access Control (RBAC) is essential to ensure data integrity, interoperability, and security across distributed systems. The interaction between actors and central DPP system functions introduces potential failure points, particularly where access permissions or sequencing logic are not clearly defined in the legislation. Moreover, uncertainties within the standardization process, combined with the limited timeframe for mandatory regulatory implementation, increase the complexity of establishing a compliant and reliable DPP infrastructure. In this context, the DPP ecosystem illustrates the extent to which regulatory requirements, technical system design, and stakeholder coordination must align to create a secure and interoperable foundation for product governance in Europe.
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