Certification bodies are about to face a problem they did not design their workflows for.
The EU Battery Regulation and ESPR framework require third-party verification of Digital Product Passport data. That means notified bodies and certification organisations will need to verify not just whether a product meets a standard, but whether the data in its digital passport is accurate, complete, and traceable to source evidence.
This is a fundamentally different verification task. And the infrastructure most certification bodies rely on today is not built for it.
The verification gap
Traditional product certification follows a familiar pattern. The manufacturer submits documentation. The certification body reviews it. An assessor may visit the facility. A certificate is issued. Surveillance audits happen periodically.
The documentation is typically a defined set of test reports, quality management records, and technical files. The scope is bounded. The format is known. The process is established.
DPP verification is different in three important ways.
First, the data volume is higher. A single battery passport contains up to 90 data fields spanning electrochemistry, carbon footprint, recycled content, supply chain due diligence, and performance characteristics. Each field needs source evidence. That is 90 verification points per SKU, not per product family.
Second, the data is dynamic. DPP data is not a static technical file. It includes lifecycle information, state-of-health updates, and supply chain changes. Verification is not a one-time event. It is ongoing.
Third, the data comes from multiple sources. The manufacturer provides some data. Suppliers provide material composition. Test laboratories provide performance data. Each source needs its own chain of evidence.
The PDF problem
Here is what DPP verification looks like today for most certification bodies: a manufacturer emails a PDF containing their draft passport data. The certification body opens the PDF. An assessor manually cross-references each data point against supporting documents — which may also be PDFs, spreadsheets, or scanned images.
The assessor has no efficient way to verify whether the data in field 47 of the passport actually matches page 12 of the test report from Laboratory X. They are manually navigating between documents, checking values, and recording their findings in a separate system.
This does not scale. When the February 2027 deadline hits and hundreds of manufacturers submit thousands of SKUs for verification simultaneously, the PDF-and-email approach will collapse under its own weight.
Why the data platform matters
The question is not whether certification bodies will need technology to handle DPP verification. They will. The question is whether they will use their own separate system, or whether they will operate on the same platform where the data was created.
There is a strong argument for the latter.
When a certification body operates on the same platform as the manufacturer, they get direct access to the source evidence. Every data field in the passport links to the specific document, page, and paragraph where the data was extracted. The assessor does not need to request supporting documents. They click on a data point and see the source.
This is not a convenience feature. It is a structural advantage that changes the economics and reliability of verification.
Consider the audit trail. When data is created on one platform, exported as a PDF, emailed to a certification body, and imported into their system, the chain of custody is broken. The certification body is verifying a copy, not the original. Any discrepancy between the manufacturer’s system and the exported document is invisible.
When the certification body operates on the same platform, they verify the original data with its original source links. The chain of custody is unbroken. The audit trail is immutable.
What verifier infrastructure looks like
A platform built for certification bodies — not just for manufacturers — includes specific capabilities that generic compliance tools do not have.
A prioritised verification queue that lets assessors work through submissions systematically, not by searching through email threads. Evidence-linked review where every data point connects to its source document with a single click. Immutable audit trails that record every verification decision, every data change, and every approval with timestamps and assessor identity. Workflow tools that match how certification bodies actually operate — review, query, conditional approval, rejection with specific deficiency notes.
These are not nice-to-have features bolted onto a manufacturer-facing tool. They are infrastructure designed for the verification workflow from the ground up.
The business case for certification bodies
DPP verification is a new revenue stream for certification bodies. The organisations that can verify at scale — quickly, reliably, and with defensible evidence trails — will capture the market as the February 2027 deadline approaches.
The organisations that try to handle DPP verification with email, PDFs, and manual cross-referencing will hit capacity limits. They will be slow. Manufacturers will go elsewhere.
The infrastructure choice is a competitive choice. The certification bodies that invest in verification infrastructure now will be the ones that scale with the regulation.
The data sovereignty question
Where the data lives matters. DPP data contains commercially sensitive information about supply chains, material compositions, and manufacturing processes. Certification bodies have obligations around data handling, impartiality, and confidentiality.
A compliant verification platform must host data in the EU, comply with GDPR, and provide clear data ownership boundaries. The manufacturer owns their data. The certification body has access for verification purposes. The platform is infrastructure, not a data owner.
This is not a detail to sort out later. The European Commission is watching how the verification ecosystem develops. Certification bodies that can demonstrate robust data governance will have an advantage in accreditation discussions.
The time to build is now
The verification demand spike is coming in Q3-Q4 2026 as manufacturers rush to comply before February 2027. Certification bodies that wait until then to figure out their DPP verification infrastructure will be building the plane while flying it.
The ones that invest now will be ready. And ready, in a market where everyone is scrambling, is a significant competitive advantage.
