UPPS Standard

Universal Product Passport Standards (UPPS)

Version 1.0 — Draft

Effective: TBD

Regulatory Mapping Framework (RMF)

Establishes a structured approach for aligning UPPS disclosures with regulatory requirements across jurisdictions.

The UPPS Regulatory Mapping Framework defines how UPPS disclosures are aligned with regulatory requirements across jurisdictions.

1

Introduction

The UPPS Regulatory Mapping Framework (RMF) establishes a structured approach for aligning UPPS disclosures with regulatory requirements across jurisdictions.

Regulatory requirements relating to product-level information are expanding globally. However, these requirements are defined inconsistently across jurisdictions, resulting in fragmentation, duplication, and increased complexity for organizations.

The UPPS RMF provides a systematic method for mapping UPPS disclosures to regulatory requirements without embedding jurisdiction-specific rules within the core standard.

This enables UPPS to function as a global disclosure framework that supports regulatory interoperability while maintaining neutrality.

2

Objective

The objective of the UPPS Regulatory Mapping Framework is to:

  • Enable alignment between UPPS disclosures and regulatory requirements
  • Reduce duplication in product-level reporting
  • Support multi-jurisdiction compliance through a unified disclosure approach
  • Provide transparency in how UPPS disclosures relate to regulatory obligations

The RMF establishes a consistent structure for mapping disclosures across jurisdictions.

3

Scope

The UPPS RMF applies to all UPPS disclosures, including:

  • UPPS 101 — General Product Disclosures
  • UPPS 201 — Environmental Product Disclosures
  • UPPS 301 — Circularity Product Disclosures
  • UPPS 401 — Supply Chain and Traceability Disclosures

The RMF covers mapping to:

  • National regulations
  • Regional regulations
  • Voluntary standards
4

Conceptual Approach

The UPPS RMF is based on a separation between:

  • Disclosure requirements (defined by UPPS)
  • Regulatory obligations (defined by jurisdictions)

UPPS defines how product-level information should be disclosed.

Regulations define what information must be disclosed.

The RMF connects these two layers through structured mapping.

This approach ensures that UPPS remains regulation-neutral while enabling regulatory alignment.

5

Mapping Structure

Mappings shall be defined at the level of individual disclosures.

Each UPPS disclosure shall be linked to relevant regulatory requirements.

5.1Mapping Elements

Each mapping shall include:

  • UPPS Disclosure Reference (e.g., UPPS 201-5.1)
  • Regulatory Framework
  • Jurisdiction
  • Regulatory Requirement Reference
  • Mapping Type
  • Notes and Interpretation

5.2Mapping Types

Mappings shall be classified as:

Direct Mapping

The UPPS disclosure fully satisfies the regulatory requirement

Partial Mapping

The UPPS disclosure partially satisfies the regulatory requirement

Supplementary Mapping

Additional information is required beyond the UPPS disclosure

5.3Granularity

Mappings shall be defined at a level of detail that enables:

  • Clear interpretation
  • Consistent application
  • Traceability between UPPS and regulatory requirements
6

Mapping Methodology

Organizations applying the RMF shall:

  1. Identify applicable regulatory requirements
  2. Map relevant UPPS disclosures to those requirements
  3. Identify gaps where UPPS disclosures do not fully satisfy requirements
  4. Provide supplementary disclosures where necessary

The mapping process shall be documented and transparent.

7

Presentation of Mappings

Mappings shall be presented in a structured format that enables clear interpretation.

This may include:

  • Tabular formats
  • Digital mapping tools
  • Integrated product passport systems

Mappings shall be accessible to relevant stakeholders, including regulators and auditors.

8

Use of the RMF

The RMF may be used by:

  • Organizations preparing disclosures
  • Regulators evaluating compliance
  • Technology providers building systems
  • Auditors verifying disclosures

The RMF enables consistent interpretation of how UPPS disclosures align with regulatory requirements.

9

Maintenance and Updates

Mappings shall be maintained and updated as:

  • Regulations evolve
  • New jurisdictions introduce requirements
  • UPPS standards are updated

Updates shall be version-controlled and documented.

10

Regulatory Alignment

The UPPS RMF supports alignment with regulatory frameworks globally, including but not limited to:

  • Ecodesign for Sustainable Products Regulation (ESPR)
  • Other product-related disclosure regulations

The RMF enables UPPS to function as a common disclosure layer across jurisdictions.

11

Limitations

The RMF does not replace regulatory requirements.

Organizations remain responsible for ensuring full compliance with applicable regulations.

The RMF provides guidance on alignment but does not constitute legal interpretation.