Making Up Goods: The Digital Product Passport in EU Market Governance

In this paper, we examine the European Union’s Digital Product Passport (DPP), a regulatory initiative to standardize, structure, and govern product information across the EU’s single market. The product passport is a new policy instrument intended to be mandatory for all products produced in and imported into the EU. Rooted in the EU Green Deal, it operates as a hidden infrastructural technology to redefine what a product is by specifying which data should accompany it across value chains and life cycles. Driven by policy ambitions associated with the circular economy and traceability, the DPP positions information as a key lever for environmental governance and market transformation. The DPP remains unexplored in social scientific research, but offers a rich case for deepening our understanding of how ideas of the circular economy influence EU market governance. We examine the DPP’s emergence as an ongoing, multisited negotiation within loosely coupled technocratic networks of researchers, industry representatives, public authorities, management consultants, standardization bodies, and others. Within these networks, standards, policy goals, and market considerations are shaped for the exchange of goods in the world’s largest free trade area. How these negotiations unfold has far-reaching implications for markets, competition, and what comes to be recognized as legitimate products. We contrast this with historical studies of the passport, which show how states developed the capacity to regulate human movement through administrative standardization of human identity, to uncover the dominant knowledge frames that underpin the development of a new authoritative understanding of a “good” and its properties in the circular economy. Empirically, we study the development and enactment of the DPP through a qualitative case study, drawing on interviews with actors from academia, the public sector, and private industry. In addition, we conduct a content analysis of industry podcasts and policy- and standard-related documents. This multi-source approach allows us to analyze how the idea of a (good) product is shaped and reshaped through the introduction of DPP by tracing how ideas, expectations, and concerns circulate across different arenas and actor groups. Our analysis suggests that the DPP is a malleable infrastructure that contributes to the formation of new roles such as users, administrators, and specialized consultancy. The DPP is characterized by openness and flexibility, enabling it to serve different policy goals over time. While originating in the circular economy, the DPP is increasingly being drawn into border regulations, geopolitical struggles, and protectionism. Actors involved in processes of framing the technology partially diverge in their objectives, expectations, and interpretations of what the DPP should achieve. Furthermore, we observe that large firms across several industries appear actively involved in the regulatory process, raising questions about regulatory capture. Significant concerns have been raised about allocating responsibility to guarantee that the information provided through the DPP is correct. By exploring the emerging infrastructure of the DPP, we conclude that the making up of ideal (circular) products is characterized by potentially conflicting objectives: traceable and accountable, yet circular and flexible.