Key takeaways
- ●Start with scope and data ownership, not software.
- ●Supplier data is usually the longest lead-time item.
- ●Pilot with real missing-data cases before you scale.
The eight steps
- 1. Confirm legal scope — product families, markets, applicable laws and dates.
- 2. Assign the responsible operator, programme owner and data owners.
- 3. Map existing data in ERP, PLM, PIM, LCA tools and supplier files.
- 4. Run a field-level gap assessment and plan supplier collection.
- 5. Decide granularity, identifiers, carriers and access policies.
- 6. Pilot representative products, including missing-data cases.
- 7. Test scans, permissions, updates, exports and lifecycle handovers.
- 8. Scale with monitoring, evidence retention and exit/continuity provisions.
Typical timeline
| Phase | Duration (indicative) |
|---|---|
| Scoping & gap analysis | 1–3 months |
| Supplier data collection | 3–12 months |
| Pilot | 1–3 months |
| Rollout | 3–9 months |
Lesson from batteries
Volvo and Circulor's EX90 battery passport took more than five years of development — publishing a passport is quick; establishing the supply-chain visibility behind it is not.
Sources
Last reviewed 2 November 2026. Guidance only — not legal advice.