Digital Product Passports Are Going Global: What China, Vietnam, and the UAE Are Building Outside the EU

Talk to most compliance teams about the Digital Product Passport and the conversation defaults to Brussels. That's no longer the whole picture. Over the past eighteen months, several governments outside the EU have moved from pilot to operational traceability systems of their own - built for different reasons, with different data, and not automatically compatible with what ESPR requires. Here's what's actually running today.

China: live since April 2026, but built for a different job

China's national battery traceability system for new-energy-vehicle (NEV) batteries has been operational since 1 April 2026, under the "Interim Measures for the Management of Recycling and Comprehensive Utilization of Waste NEV Power Batteries." It assigns a unique digital identity to each battery and tracks it through production, integration, use and recycling - full lifecycle traceability, in the same functional shape as the EU's own Battery Passport (tilkal.com).

The purpose is different, though, and that difference matters for anyone assuming the two systems will simply interoperate. China's system is built around industrial supervision, recycling control and product safety governance - a state oversight tool for a strategic material stream - rather than the consumer-facing sustainability transparency that anchors ESPR's Digital Product Passport. Same shape, different job. A battery that's fully compliant with China's traceability regime does not thereby satisfy the EU Battery Passport's data requirements under Regulation (EU) 2023/1542, and vice versa - the data models were built for different regulators asking different questions.

Vietnam: risk-tiered traceability, live since January 2026

Vietnam took a different legislative route. Amendments to its Law on Products and Goods Quality, adopted in June 2024, took effect on 1 January 2026 and introduced a risk-based classification system - products sorted into low, medium and high-risk tiers. High-risk products now require digital traceability through a national platform, using QR codes and barcodes, and the requirement applies equally to domestic production and imports (tilkal.com).

For manufacturers who export into both the EU and Vietnam, that's two separate traceability obligations layered on the same physical product - built on different legal bases, different risk logic, and (so far) no mutual recognition arrangement between them.

The UAE: mandatory passports for construction steel

The UAE has gone narrower and sector-specific: a mandatory Digital Product Passport for construction steel products, framed around transparency, quality assurance, sustainability reporting and product traceability (tilkal.com). It's a useful data point precisely because it's narrow: it shows the DPP concept being adopted piecemeal, sector by sector, by regulators who aren't building a horizontal framework the way the EU has with ESPR - they're solving one supply chain's traceability problem at a time.

The US and the "DPP-adjacent" category

The United States doesn't have a national digital product passport, and nothing currently proposed looks like one. What it has instead are sector rules that function similarly without sharing the branding. The FDA's Food Safety Modernization Act Section 204 requires standardized digital recordkeeping for high-risk foods, and US Customs and Border Protection has its own modernization initiatives around import data. Both are "DPP-adjacent" - digital, traceable, standardized - without being a true passport system tied to a persistent product identity across its full lifecycle (tilkal.com).

Japan and South Korea sit a step earlier again: government-supported battery passport pilots and demonstrations exist in both countries, but neither has a mandatory nationwide regulation yet.

Why the convergence talk is ahead of the reality

There's a real push toward "mutual recognition" rhetoric - Chinese standards experts in particular have signalled interest in aligning their national DPP roadmap with the EU's approach specifically to reduce duplicate compliance costs for exporters (renoon.com). That's a sensible goal and it is not close to being realised. What exists today is five or six jurisdictions building traceability infrastructure independently, on their own timelines, for their own regulatory purposes, with no binding equivalence agreement between any of them and ESPR. "Global convergence toward product data requirements" is a fair description of the direction of travel; it is not yet a description of the compliance landscape a multinational manufacturer actually operates in.

What this means if you sell into more than one of these markets

If your products move through the EU and any of China, Vietnam or the UAE, the practical position today is that you are managing parallel, non-equivalent traceability obligations, not one passport with regional flavours. Three things follow from that:

1. Don't assume ESPR compliance travels. A DPP built to EN 18220 and the other CEN/CENELEC standards for the EU market satisfies EU law. It does not automatically satisfy China's NEV battery traceability measures, Vietnam's risk-tiered platform, or UAE steel requirements - each has its own data fields, carrier requirements and registry.
2. Build your underlying data model wider than ESPR demands, even if you only publish the EU-required subset today. The material, component and lifecycle data most of these regimes ask for overlaps substantially even where the exact schema differs - collecting it once, at the bill-of-materials level, is cheaper than re-collecting it per jurisdiction later.
3. Watch the mutual-recognition conversation, but don't plan around it. If the EU and China (or others) do reach an equivalence arrangement, it will be a negotiated, sector-specific outcome, not a blanket one - the way most regulatory mutual recognition actually works. Until a specific arrangement is signed, treat each jurisdiction's passport as its own compliance track.

The Digital Product Passport stopped being a uniquely European idea sometime in the last year. It has not yet become a single global standard - and for now, that gap is exactly where the compliance work lives.