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UPPS Standard

Universal Product Passport Standards (UPPS)

Version 1.0

Effective: May 2026

UPPS 401: Supply Chain and Traceability Disclosures

Establishes disclosure requirements for supply chain transparency and traceability of products under the Universal Product Passport Standards (UPPS).

UPPS 401 defines the disclosure requirements for supply chain information that organizations shall provide to ensure transparency and traceability.

[NORMATIVE]

Sections 1-10 contain normative requirements that shall be followed for UPPS 401 compliance. Guidance sections provide non-binding recommendations.

1

Introduction

UPPS 401 establishes disclosure requirements relating to the supply chain and traceability of products.

This Standard defines the disclosures necessary to enable consistent, comparable, and decision-useful information regarding the origin, movement, and transformation of products and their components across the value chain.

Supply chain transparency is a critical component of product-level accountability. Increasing regulatory requirements and stakeholder expectations require organizations to disclose information on sourcing, supplier networks, and the traceability of materials and components.

UPPS 401 provides a structured framework for such disclosures, enabling alignment across jurisdictions and supporting regulatory implementation, including compatibility with frameworks such as the European Union's Ecodesign for Sustainable Products Regulation (ESPR) and due diligence regulations.

2

Objective

The objective of UPPS 401 is to ensure that organizations disclose information that enables users to:

  • Understand the origin of products and their components
  • Trace the movement of materials and products across the value chain
  • Assess supply chain risks and dependencies
  • Evaluate sourcing practices and supply chain transparency

UPPS 401 establishes consistent requirements for supply chain and traceability disclosures that support transparency, accountability, and comparability.

3

Scope

UPPS 401 applies to all products for which supply chain and traceability information is disclosed under UPPS.

Organizations shall apply this Standard in conjunction with:

  • UPPS 101 — General Product Disclosures
  • UPPS 201 — Environmental Product Disclosures
  • UPPS 301 — Circularity Product Disclosures

Disclosures shall cover the relevant stages of the value chain, including:

  • Raw material sourcing
  • Component manufacturing
  • Assembly
  • Distribution

Where full traceability is not feasible, organizations shall disclose the extent of coverage and limitations.

4

General Requirements

4.1Basis of Disclosure

Organizations shall disclose the methodologies and systems used to collect and manage supply chain information.

This may include internal systems, supplier reporting, and third-party data sources.

4.2Boundaries

Organizations shall define:

  • Supply chain tiers included in disclosures
  • Product components covered
  • Geographic boundaries

4.3Data Quality and Verification

Organizations shall disclose:

  • Source of supply chain data (supplier-provided, estimated, verified)
  • Level of verification or assurance

Where traceability is partial, organizations shall clearly indicate data gaps.

4.4Level of Traceability

Organizations shall disclose the level of traceability achieved, including:

  • Tier-level visibility (e.g., Tier 1, Tier 2, Tier 3)
  • Material-level traceability, where applicable
5

Supply Chain and Traceability Disclosures

Organizations shall disclose the following information for each product.

5.1Supplier IdentificationUPPS 401.5.1

Disclosure Requirement

Organizations shall disclose information relating to key suppliers involved in the production of the product.

Required Disclosures

  • Identification of Tier 1 suppliers
  • Geographic location of suppliers
  • Nature of supplied components or materials

Guidance

[INFORMATIVE]

[INFORMATIVE]

Supplier disclosures should enable understanding of the primary actors within the supply chain.

5.2Origin of MaterialsUPPS 401.5.2

Disclosure Requirement

Organizations shall disclose the origin of primary materials used in the product.

Required Disclosures

  • Country or region of origin of key materials
  • Source of raw materials, where known
  • Critical materials, where applicable

Guidance

[INFORMATIVE]

[INFORMATIVE]

Material origin disclosures should support traceability and risk assessment.

5.3Supply Chain StructureUPPS 401.5.3

Disclosure Requirement

Organizations shall disclose the structure of the supply chain.

Required Disclosures

  • Number of supply chain tiers covered
  • Key stages in the supply chain
  • Relationships between suppliers, where relevant

Guidance

Disclosures shall enable users to understand the complexity and depth of the supply chain.

5.4Traceability of ComponentsUPPS 401.5.4

Disclosure Requirement

Organizations shall disclose the extent to which components and materials can be traced.

Required Disclosures

  • Components or materials with traceability
  • Level of traceability (e.g., batch-level, supplier-level)
  • Limitations in traceability

Guidance

Traceability disclosures shall reflect actual capabilities rather than theoretical potential.

5.5Sourcing PracticesUPPS 401.5.5

Disclosure Requirement

Organizations shall disclose information relating to sourcing practices.

Required Disclosures

  • Sourcing policies or standards applied
  • Use of certified or verified suppliers, where applicable
  • Consideration of environmental and social factors in sourcing

Guidance

[INFORMATIVE]

[INFORMATIVE]

Disclosures should support evaluation of responsible sourcing practices.

5.6Supply Chain RisksUPPS 401.5.6

Disclosure Requirement

Organizations shall disclose known or potential risks within the supply chain.

Required Disclosures

  • Geographic or sector-specific risks
  • Dependency on critical suppliers or materials
  • Identified supply chain disruptions or vulnerabilities

Guidance

[INFORMATIVE]

[INFORMATIVE]

Risk disclosures should enable assessment of resilience and exposure.

5.7Due Diligence and MonitoringUPPS 401.5.7

Disclosure Requirement

Organizations shall disclose processes for monitoring and managing supply chain performance.

Required Disclosures

  • Due diligence processes applied
  • Monitoring mechanisms
  • Corrective actions taken, where relevant

Guidance

[INFORMATIVE]

[INFORMATIVE]

Disclosures should reflect the extent to which organizations actively manage supply chain risks.

6

Presentation of Information

Organizations shall present supply chain and traceability disclosures in a manner that is:

  • Clear and understandable
  • Consistent across products and reporting periods
  • Aligned with other UPPS disclosures

Disclosures shall enable users to understand both the structure of the supply chain and the level of transparency achieved.

7

Effective Date

UPPS 401 is effective for disclosures published after [To be determined].

Early adoption is permitted.

8

Relationship with Other UPPS Standards

UPPS 401 shall be applied together with:

  • UPPS 101 — General Product Disclosures
  • UPPS 201 — Environmental Product Disclosures
  • UPPS 301 — Circularity Product Disclosures
9

Transition Provisions

Organizations may adopt UPPS 401 progressively.

Where full traceability is not available, organizations shall disclose:

  • Scope of traceability achieved
  • Data limitations
  • Plans to improve traceability
10

Regulatory Alignment

UPPS 401 is designed to support alignment with supply chain transparency and due diligence regulations across jurisdictions.

This includes compatibility with:

  • Ecodesign for Sustainable Products Regulation (ESPR)
  • Supply chain due diligence regulations

UPPS 401 enables organizations to structure supply chain disclosures in a manner that can be mapped to regulatory requirements, improving consistency and reducing duplication.

Compliance Checklist

[INFORMATIVE]

This checklist provides a summary of key compliance requirements for UPPS 401. Refer to the normative sections above for complete requirements.

Supplier Identification (UPPS 401.5.1)

  • Disclose identification of Tier 1 suppliers
  • Disclose geographic location of suppliers
  • Disclose nature of supplied components or materials

Origin of Materials (UPPS 401.5.2)

  • Disclose country or region of origin of key materials
  • Disclose source of raw materials, where known
  • Disclose critical materials, where applicable

Supply Chain Structure (UPPS 401.5.3)

  • Disclose number of supply chain tiers covered
  • Disclose key stages in the supply chain
  • Disclose relationships between suppliers, where relevant

Traceability of Components (UPPS 401.5.4)

  • Disclose components or materials with traceability
  • Disclose level of traceability (e.g., batch-level, supplier-level)
  • Disclose limitations in traceability

Sourcing Practices (UPPS 401.5.5)

  • Disclose sourcing policies or standards applied
  • Disclose use of certified or verified suppliers, where applicable
  • Disclose consideration of environmental and social factors in sourcing

Supply Chain Risks (UPPS 401.5.6)

  • Disclose geographic or sector-specific risks
  • Disclose dependency on critical suppliers or materials
  • Disclose identified supply chain disruptions or vulnerabilities

Due Diligence and Monitoring (UPPS 401.5.7)

  • Disclose due diligence processes applied
  • Disclose monitoring mechanisms
  • Disclose corrective actions taken, where relevant
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