Automating Accountability: Smart Contracts and the Legal Future of Digital Product Passports in the EU Circular Economy

The European Union’s 2050 climate neutrality target relies heavily on circular economy strategies, with the newly introduced Ecodesign for Sustainable Products Regulation (ESPR) establishing Digital Product Passports (DPPs) as a key tool to close information gaps in product lifecycles. Despite the regulatory momentum, the scalability of DPPs across diverse sectors - such as batteries by 2027 and textiles by 2030 - poses significant challenges for data management and compliance verification. Methodologically, the study applies a multi-layered doctrinal-comparative framework triangulating EU law, CJEU jurisprudence, and industry pilot projects. This approach reveals that smart contracts, as automated executors of predefined conditions, can effectively govern DPP data, enhancing transparency and operational efficiency. Pilot initiatives by the Global Battery Alliance and textile industry experiments demonstrate the practical viability of blockchain-enabled smart contract automation for sustainability data collection, supplier verification, and regulatory compliance. The findings underscore the transformative potential of integrating legal frameworks with emerging digital technologies to support circular economy objectives. However, the study also highlights unresolved legal complexities concerning data access, liability, and regulatory oversight. These insights inform policymakers and industry stakeholders on designing robust, scalable, and legally compliant DPP systems, advancing the EU’s sustainability agenda through innovative digital governance mechanisms.