Cross-Border E-commerce to Consumers: How Digital Product Passports Could Strengthen EU Product Compliance

Billions of products enter the European Union through online shopping every year, often arriving directly at consumers’ doorsteps from sellers outside the EU. For customs and market surveillance authorities, ensuring that these products meet European safety and sustainability requirements is becoming increasingly difficult. A white paper developed in collaboration with PARSEC, CIRPASS-2, BORDERLINK EU Funded projects explores how Digital Product Passports (DPPs) could help authorities access reliable product information, identify compliance risks and improve oversight of cross-border e-commerce. Here are the key takeaways from the white paper.

The Growing Challenge of Cross-Border E-commerce

Cross-border online shopping has transformed the way products reach European consumers. International marketplaces make it possible to order clothing, electronics, toys and countless other goods directly from sellers around the world, often at remarkably low prices.

The scale of these transactions is growing rapidly. According to the European Commission, 4.6 billion low-value items, worth no more than €150 each, entered the EU in 2024, nearly twice the 2.4 billion recorded in 2023. This represents approximately 12 million parcels or items per day.

Whereas for consumers, this development brings greater choice and convenience, for European authorities, it creates an enormous challenge. Every product entering the EU must comply with applicable European requirements, regardless of where it was manufactured or how it was purchased. These requirements can cover product safety, chemical substances, environmental performance, labelling and other obligations. Yet the sheer volume of individual shipments makes comprehensive physical inspections impossible.

The consequences are already visible. A coordinated EU investigation involving around 200 market surveillance authorities examined a sample of 30,000 imported products sold through 25 online marketplaces. More than 50% of the sampled products failed to comply with EU market requirements. The investigation covered categories including toys, cosmetics, electronics, food supplements and personal protective equipment.

These findings raise concerns about consumer safety and fair competition. European manufacturers invest in meeting regulatory requirements, while non-compliant imports can reach the same customers without bearing equivalent compliance costs. As online trade continues to expand, authorities need better ways to identify risks and verify product compliance.

Why Traditional Product Compliance Checks Are No Longer Enough

The EU has established systems to protect consumers and ensure that products placed on its market comply with applicable regulations. Customs authorities oversee goods entering the EU, while market surveillance authorities monitor whether products available on the market meet legal requirements. Both play essential roles, but cross-border e-commerce makes their work increasingly complex.

Traditional import processes often involve larger commercial shipments handled by established importers. In direct-to-consumer e-commerce, thousands of small consignments may arrive from different sellers, manufacturers and fulfilment centres. Responsibility can also be difficult to establish. Depending on the transaction and applicable legislation, several parties may be involved, including manufacturers, online marketplaces, sellers, importers and authorised representatives.

Once a parcel has cleared customs, it may be delivered directly to a consumer. This leaves market surveillance authorities with limited opportunities to intervene before the product reaches its destination.

Another challenge is access to reliable information. Product documentation may be distributed across different systems, provided in inconsistent formats or unavailable when authorities need it. Without sufficient information, identifying potentially unsafe or non-compliant products becomes difficult, particularly when authorities must process millions of shipments. This is where Digital Product Passports could make a difference.

How Digital Product Passports Could Make a Difference

Digital Product Passports are being introduced under several EU regulations, including the Ecodesign for Sustainable Products Regulation (ESPR), the EU Battery Regulation and the Construction Products Regulation.

A DPP provides digital access to information about a product, with the specific data requirements determined by the legislation applicable to its product group. Depending on those requirements, this may include information about materials, environmental performance, technical characteristics, conformity documentation and other relevant product attributes. While DPPs are closely associated with sustainability and circular economy objectives, their potential extends to product compliance monitoring. For cross-border e-commerce, they could provide authorities with a more consistent way to access the information needed to assess products entering the EU market.

Making Product Information Accessible and Transparent

Today, product information is often fragmented across manufacturers, suppliers, importers and online platforms. Digital Product Passports could help connect this information through standardised digital records linked to identifiable products. Rather than requesting documentation separately from different economic operators, authorised stakeholders could access relevant information through the DPP infrastructure, subject to applicable access rights. Who would benefit from this:

• For customs authorities, this could mean obtaining product information earlier in the import process. 

• For market surveillance authorities, it could simplify access to compliance documentation and support more consistent checks across EU member states. 

• For online marketplaces, DPPs could offer a more structured basis for obtaining and presenting product characteristics to consumers.

However, the availability of a DPP does not automatically establish that a product complies with EU law. The information must be accurate, sufficiently detailed and suitable for the checks authorities need to perform.

Supporting Smarter Customs and Market Surveillance

One of the most promising opportunities is the use of DPP data in risk assessment. Customs authorities cannot physically inspect every incoming parcel. Instead, they rely on risk management to identify shipments that warrant closer examination. Access to structured, machine-readable product information could strengthen these processes.

For example, authorities could potentially compare product information with applicable regulatory requirements, identify missing documentation or flag inconsistencies for further investigation. Digital information could also improve cooperation between customs and market surveillance authorities. Where relevant information is available before goods are released into the EU market, authorities may be better positioned to identify compliance concerns earlier.

The Missing Piece: Can Digital Product Passport Data Be Trusted?

Making product information accessible is an important first step. But its usefulness depends on whether that information can be trusted. A Digital Product Passport may contain declarations about a product's composition, origin, environmental characteristics or compliance status. Authorities must be able to assess whether those declarations are credible.

Who provided the information? Is the issuer authorised to make the claim? Has the information been independently verified? And is it still valid?

These questions become particularly important in international supply chains, where information may originate from numerous organisations operating under different regulatory frameworks.

From Product Data to Verifiable Evidence

There are different levels of confidence that a Digital Product Passport can provide.

At a basic level, information may be available in a standardised format. More advanced approaches could enable authorities to establish where particular claims originated and whether they have been verified by a trusted third party.

For example, a manufacturer might provide product characteristics, while an authorised certification body issues evidence confirming that specific requirements have been met. Technologies such as Verifiable Credentials help establish the authenticity and origin of such evidence, allowing relevant claims to be checked digitally. European Business Wallets will also support trusted interactions between organisations by enabling them to present and verify digital credentials. These approaches are particularly relevant when information needs to be exchanged securely between manufacturers, suppliers, certification bodies, marketplaces and public authorities.

Full implementation of the DPP will be a gradual development, starting with accessible product data and progressing towards stronger identity, access control and verification mechanisms making compliance information increasingly useful for both businesses and authorities.

What This Means for Businesses, Authorities and Consumers

The potential benefits of better product information extend across the e-commerce ecosystem:

For manufacturers and importers, Digital Product Passports could create a more consistent way to provide regulatory information to business partners and authorities. This may reduce repeated documentation requests and support more efficient compliance processes.

For online marketplaces, access to structured product data could improve the quality and consistency of product information. It may also support future approaches to checking compliance documentation, depending on how platform responsibilities develop.

For customs and market surveillance authorities, machine-readable information could support more targeted inspections, better risk assessment and improved coordination. This would be particularly valuable given the growing volume of small shipments.

For consumers, greater transparency could make it easier to understand product characteristics and make informed purchasing decisions.

Smaller businesses also need to be considered. DPP implementation must remain manageable for companies with limited technical resources, particularly where product data must be collected from international suppliers. Achieving these benefits will depend on practical implementation, interoperable systems and clear rules for accessing and verifying information.

Building a More Transparent and Trusted EU Single Market

The rapid growth of cross-border e-commerce is placing increasing pressure on Europe's product compliance systems. Digital Product Passports offer a promising foundation for making product information more accessible, consistent and potentially verifiable across international supply chains. Their value for authorities will ultimately depend on the reliability of the information they contain, the ability to process it efficiently and the cooperation of the organisations responsible for providing and checking it. As EU regulations and digital infrastructure continue to evolve, connecting Digital Product Passports with customs and market surveillance processes could become an important step towards safer products, fairer competition and a more transparent European Single Market.

Explore More in the Full Research Paper

This article draws on the collaborative white paper “Cross-Border E-commerce to Consumers, Digital Product Passports (DPP), and the Role of Authorities,” developed through the PARSEC, CIRPASS-2, BORDERLINK initiatives and the Cross-Project DPP Authorities Working Group. The paper examines the legislative context, cross-border e-commerce processes, the responsibilities of customs and market surveillance authorities, and the technical opportunities and challenges surrounding verifiable Digital Product Passports.

Read the full white paper here.