The regulatory environment is in a critical state of flux. In the U.S., a state-by-state approach to extended producer responsibility (EPR) regulations is taking shape. In Europe, comprehensive legislation around product sustainability is coming into force with the adoption of the Ecodesign for Sustainable Products Regulation (ESPR), which will introduce the Digital Product Passport (DPP) and require detailed supply chain data on everything from electronics to pharmaceuticals to apparel.
For companies and brands with a regional or international footprint of any size, navigating the complexities of new and changing regulations can be overwhelming — but it doesn’t have to be. The key is to incorporate traceable data into their products so they can share the who, what, where and how of those products with all stakeholders.
Where can brands start? With standards-enabled digital solutions that collect and streamline product data.
For example, companies can use Global Trade Item Numbers (GTINs) and Global Location Numbers (GLNs) from GS1 US, the leading not-for-profit standards organization, to identify their products and where they have been throughout the supply chain. Data can then be shared via the Electronic Product Code Information Services (EPCIS) standard format so that all supply chain stakeholders can access product attributes and movements, no matter what tools or technology they are using.
“Companies are making significant investments in certifications and rightly want to take credit for the good they’re doing in their supply chains,” says Vivian Tai, Director of Innovation, Community Engagement, with GS1 US. “But that will only be possible when businesses tap into standards-enabled granular identification and traceability tools. With more granular identification and robust data sharing, companies can take a proactive stance and stay ahead of new and evolving regulatory requirements.
Digital Product Passports are driven by data
The recently adopted ESPR will require DPPs on many products across industries in the EU market. DPPs electronically provide relevant information about a product’s materials, lifecycle, disposal and more. This data will be stored in online databases and made available via 2D barcodes, RFID and other digital tags.
Much uncertainty remains around DPP implementation since the European Commission is still defining what information must be included. Forward-thinking companies should therefore begin the data collection process now and leverage what they have to build a foundation for compliance. “Companies often already have a system of downstream product identification, and they can associate more upstream product information with this data,” Tai says.
Utilizing EPCIS is critical to these efforts because it streamlines data sharing across the entire supply chain, which will be necessary under ESPR and rules for DPPs. EPCIS works with different data repositories and supports interoperability between systems. “It provides a common language so that if Company A and Company B use different technologies and tools, those systems can refer to the same supply chain events with consistency,” Tai says.
By leveraging EPCIS, regulators, consumers and all stakeholders can gain visibility into the physical journey of a product as it moves from one location to the next. They can access that data through QR codes, RFID, or other tags and barcodes, which means brands and producers will be ready to meet DPP regulations as soon as they’re in place.
Traceability supports EPR readiness
It’s not just companies with an international presence that need to stay vigilant about changing regulations. In the U.S., five states currently have EPR laws on the books, and four more have introduced legislation in 2025.
“Various EPR regulations are in different stages of implementation across several states, creating a patchwork of requirements that will create challenges for companies as they work toward compliance,” says Maggie Lyons, VP of Government and Regulatory Affairs with GS1 US.
These regulations require brands to share key attributes about their products and packaging with producer responsibility organizations (PROs). Traceability data and unique product identifiers are critical because they can help ensure provenance and include information about raw materials, percentages of recycled or recyclable materials, or other disposal information such as compostability. PRO stakeholders can then accurately determine fees and obligations under various EPR laws.
As with DPPs, EPCIS can support the necessary data sharing so that companies can provide data to any and all stakeholders, even under different regulatory schemes in different states. This granularity prepares brands to meet, for example, stringent regulations in a state like California, as well as less specific rules in states just beginning to implement EPR. And the interoperability of EPCIS means that stakeholders in any state or PRO can access a company’s data.
Managing regulatory uncertainty is possible
The current regulatory environment is changing in unprecedented ways. Brands and producers should consider implementing strong data-gathering and data-sharing practices today to address uncertainty and reduce the risk of non-compliance. The key starting point is to use globally unique product identification data, enabling the capture of supply chain information for every item produced.
Even in a shifting political climate, this level of traceability is important to meet the needs of diverse markets. “The federal regulatory environment may be uncertain for the remainder of 2025 and beyond, but companies need to be monitoring action at the state level,” Lyons says.
Using digital tools will allow companies in any location to satisfy current regulations and be ready for how those regulations might change in the future. Sustainability, product disposal and product authenticity will remain critical considerations for regulators and consumers alike, and brands that want to future-proof their operations will be ready with transparency and traceability to meet those needs.
Learn more about enhancing supply chain sustainability with GS1 Standards.
