Data Interoperability in European Product Conformity Management for Circular Supply Chains: Digital Twins and a Legal Knowledge & Data Model for linking law making and product manufacturing

The European Green Deal and emerging EU regulations (e. g. the Batteries Regulation and the proposed Ecodesign for Sustainable Products Regulation (ESPR)) emphasize the need for robust product compliance management to support circular economy goals. However, ensuring regulatory compliance across complex supply chains and product lifecycles remains challenging due to fragmented data silos and a lack of interoperability. In response, this paper proposes a Digital Product Compliance Management (DPCM) framework leveraging three interlinked digital twins: the Digital Regulation Document (DRD), the Digital Product Passport (DPP), and the Digital Intervention Pattern (DIP). Specifically, the DRD encapsulates regulatory requirements in a machine-readable form for automated processing and the DPP aggregates comprehensive product data (including materials, usage, and end-of-life information) across the value chain. The DIP digitizes compliance measures and its outcomes, providing a traceable audit trail of conformance. By connecting these digital twins, the DPCM framework facilitates organizational, semantic and syntactic interoperability, enabling seamless data exchange and a shared understanding of compliance information among diverse stakeholders, especially in Product Lifecycle Management (PLM) processes. The authors further “touches” Artificial Intelligence (AI) techniques, particularly Retrieval-Augmented Generation (RAG) to experiment on automatically retrieve and interpret of relevant regulatory semantic and product data for proactive compliance monitoring. A case study in Circular Economy of automotive business proofs the practical applicability of DPCM in circular economy context. Finally, the authors outlines recommendations for the enhancement of the DPP as well as future research directions specifically on data interoperability aspects in product compliance management processes.