The 11-Hour Tax: Nearly Half of Supply Chain Execs Still Aren't Ready for DPP Deadlines

Only 49% of supply chain executives say at least half of their Tier-1 suppliers can provide DPP-compliant data by 2027 — a meaningful gap given that full compliance will ultimately require verified data across both direct and upstream supplier tiers.

Most supply chain executives are already preparing for the EU’s 2027 Digital Product Passport (DPP) deadlines. 81% report allocating a dedicated budget toward compliance, and 52% say implementation is underway or nearing completion. 

To better understand where organizations stand today, Tradeverifyd surveyed 422 senior supply chain leaders across U.S. companies with EU market exposure and at least $50 million in annual revenue. The findings show that while most organizations recognize the urgency of DPP requirements, structural data disparities remain a barrier to full compliance.

Key Takeaways

• Only 54% of supply chain executives say at least half of their Tier-1 suppliers can provide DPP-compliant data by 2027. Full compliance will ultimately require verified data across both direct and upstream suppliers.
• 69% of supply chain executives say their compliance or supply teams spend 11+ hours each week translating supplier data for regulatory submissions.
• 21% of supply chain executives say real-time visibility into disruptions is their single biggest blind spot, followed by 18% who cite uncertainty about which suppliers pose the greatest regulatory or compliance risk.

With Less Than a Year Until Deadline, Companies Are Untangling Their Supply Chains 

The Digital Product Passport introduces a new requirement for structured, verifiable product-level data across upstream supplier networks and sourcing documentation. The regulation applies to any company selling regulated products into the European Union, regardless of headquarters location. That makes DPP readiness a major supply chain infrastructure issue, extending beyond regional compliance teams. 

Despite active planning efforts, nearly half (48%) of supply chain executives say their organizations have not yet reached the implementation stage of DPP readiness, and 12% report limited awareness of requirements or only early research activity.

Only one-third (34%) of supply chain executives say their organizations can trace material origin all the way to Tier-4 — the raw material or extraction point — or achieve full end-to-end traceability. That leaves two-thirds of supply chains with meaningful blind spots at or before the raw-material layer. 

For DPP purposes, this matters because the regulation's disclosure requirements are built around product-level data that must be traceable to its source: where materials originated, how they were processed, and whether sourcing practices meet applicable environmental and forced-labor standards. 

Traceability that stops at Tier-2 or Tier-3 may support internal risk monitoring but won't satisfy documentation requirements that reach back to extraction-point inputs. 

It’s also worth noting that only 2% of respondents say they can't trace beyond Tier-1 at all. The more common problem isn’t that traceability exists, but isn't in a format ready for regulatory submission. That's the operational gap the data keeps returning to.

Even direct supplier readiness remains uneven. Only 54% of respondents say at least half of their Tier-1 suppliers have confirmed they can provide DPP-compliant data by 2027. Because Tier-1 suppliers represent the closest documentation layer, incomplete confirmation at this level signals deeper upstream readiness challenges.

Organizations navigating overlapping disclosure requirements across jurisdictions already face growing documentation pressure as regulatory trends shaping the consumer product industry continue to shift expectations toward continuous traceability across supplier ecosystems.

Regulations Aren't Supply Chains' Most Notable Blocker

Regulatory complexity plays a role in DPP preparation, but our survey results show that systems integration challenges slow implementation more than regulatory uncertainty.

Twenty-seven percent of supply chain executives say IT and systems integration issues are the primary barrier to DPP readiness. Only 19% cite unclear regulatory expectations as the biggest obstacle. 

The difference between those two figures suggests most organizations have moved past the question of what DPP requires and are now confronting the harder problem of how their existing infrastructure handles it. Supplier data arrives in inconsistent formats across ERPs, spreadsheets, and proprietary portals. Standardizing that data into submission-ready records at scale requires integration work that regulatory guidance alone doesn't solve.

Organizations largely understand what DPP regulations require. The remaining challenge is connecting internal datasets with supplier documentation across multiple tiers.

Trade policy changes add another layer of complexity. Thirty-nine percent of supply chain executives say recent tariff and trade developments significantly or extremely complicate their DPP planning. Tariffs reshape sourcing decisions and supplier selection, which shape documentation requirements under DPP frameworks.

Manual data processing continues to slow readiness efforts as well. Sixty-nine percent of respondents report spending at least 11 hours each week translating supplier spreadsheets, PDFs, or unstructured documentation into standardized formats suitable for regulatory submission. 

Only 11% say their organizations operate fully integrated workflows that eliminate this translation effort entirely. That’s more than a full workday each week devoted to formatting supplier data rather than advancing compliance readiness, highlighting persistent documentation problems across supplier ecosystems.

These same pressures help explain why more companies are investing in supply chain transparency as part of broader modernization strategies. 

Organizations evaluating supply chain transparency solutions often encounter the same documentation problems, which create hidden operational overhead long before regulatory deadlines arrive.

‍Supply Chains Need More Visibility and More Streamlining to Navigate New Regulations 

Even as DPP requirements expand, many supply chain leaders still lack visibility into supplier risk and disruptions. When asked to identify the one thing they most wish they knew about their supply chain, 21% of executives named real-time visibility into supplier disruptions. Eighteen percent cited uncertainty about which suppliers pose the greatest regulatory or compliance risk.

Without consistent supplier-level mapping across tiers, organizations cannot confirm whether sourcing inputs meet evolving environmental and forced-labor disclosure requirements. 

As DPP enforcement timelines approach, supplier visibility is shifting from a compliance advantage to a baseline requirement for market access. Organizations that can't trace upstream dependencies or confirm supplier compliance status ahead of deadlines face a narrowing window to close those gaps before enforcement conditions change. The data suggests many are still in that position — investing in readiness planning while the underlying traceability infrastructure remains incomplete.

That gap is what proactive management of supplier networks is increasingly designed to address: not just tracking disruptions after they surface, but building the documentation depth that DPP frameworks will require before they're audited.

Teams preparing for upcoming disclosure requirements can request a Tradeverifyd demo to see how their multi-tier supplier mapping platform supports scalable compliance readiness across upstream supplier networks.

Methodology

The survey was conducted by Centiment for Tradeverifyd and fielded between March 5, 2026, and March 13, 2026. The results are based on 422 completed surveys. To qualify, respondents were screened as residents of the United States, aged 18 or older and employed in supply chain with a title of manager or higher, at an organization with at least $50 million in annual revenue and currently selling or planning to sell products in EU markets.

The data is unweighted with natural fallout across organization size above the $50M threshold and across industry. Respondents skew enterprise — 42% work at organizations with over $1 billion in annual revenue. The margin of error is approximately +/-5% for the total sample at a 95% confidence level.