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How do you prove a product’s ethics if no one tracks its journey? From raw materials to the customer’s hands, every product carries a story, but without verifiable traceability, even the most responsible practices can go unnoticed.
Chain of Custody (CoC) is the foundation of credible traceability in modern supply chains. As sustainability claims, regulatory scrutiny, and Digital Product Passport (DPP) requirements increase, companies must be able to prove, not just state, where products come from, who handled them, and what changed along the way.
This guide explains how chain of custody works in practice, how it differs from ownership and custody, what data and documentation it must include, and how a digital, integrated CoC model supports compliance, transparency, and accountability across the full product lifecycle.
In a supply chain, products move through multiple hands: suppliers, transporters, warehouses, and distributors. Chain of custody is the way we keep a clear, traceable record of that movement so we can show who handled the product, when it changed hands, and where it went from start to finish.
Chain of Custody is a process used to track the movement and control of an asset through its lifecycle by creating an auditable trail that documents each person and organisation who handles it, along with the date/time and purpose of each transfer.
To understand the chain of custody in supply chains, it helps to separate three ideas:
Note: In practice, the chain of custody records custody events (who physically handled the goods), while ownership or title may transfer at different points based on commercial terms. These are related but distinct records that together establish accountability.
Why does this matter?
Because disputes often happen when these concepts get mixed up. A product can be in your warehouse (custody) but still belong to a supplier (ownership). Or the buyer may own the goods once they ship, even if a carrier still has them. If a shipment arrives damaged, missing, or temperature-abused, the first question becomes: who was responsible at the moment it went wrong? Ownership and custody records help you answer that without guesswork.
A chain of custody contains a complete, chronological record of a product (or batch) as it moves through the supply chain, capturing who handled it, what happened to it, when and where each handoff occurred, and how it was safeguarded.
In practice, that means each custody event should include:
Example: In a battery or electronics supply chain, a lot of cells arriving at a manufacturing facility will have their batch IDs, supplier info, and shipment details recorded at each handoff to maintain traceability and support regulatory or sustainability claims.
The goal is an “unbroken” trail that demonstrates continuity and integrity of the item’s journey.
The ownership chain is the sequence of organisations that handle a product as it moves through the supply chain. It shows each handover from the supplier/producer to the manufacturer, then through any subcontractors involved in processing or finishing, and onward to logistics partners who transport it.
From there, custody often passes to wholesalers/distributors and then retailers. In circular supply chains, the chain can continue after sale through service providers, repair operators, and finally recycling plants that recover materials.
Each ownership (custody) change is recorded using a consistent set of details: actor identity (who handed over and who received), a handover timestamp (when it happened), a transaction ID (shipment/order/transfer reference), and transport or delivery data (carrier/tracking/proof of delivery).
In a world where supply chains are increasingly complex, relying on paper-based documentation slows down transparency and limits traceability. Every certificate, test report, and delivery note contains critical information, but without digital integration, this data remains fragmented and hard to verify. Digitising these documents not only secures the information but also makes it actionable across industries, enabling compliance, sustainability, and circularity.
All product documents, certificates (FSC, GRS, RMAP), safety datasheets, test reports, composition declarations, batch passports, invoices, and environmental footprint declarations form the Documentation Chain.
With Chain of Custody (CoC), these become:
By transforming traditional paperwork into reliable, interoperable digital assets, digital CoC empowers traceability, circularity, and operational efficiency across the entire product lifecycle.
The Integrated Digital Chain of Custody (CoC) Model brings together four critical chains: material, process, ownership, and documentation, into a single, unified digital traceability record. This ensures that every step of a product’s lifecycle is transparent, verifiable, and actionable.
With the EU’s Ecodesign for Sustainable Products Regulation (ESPR) and mandatory Digital Product Passports (DPPs) rolling out by product category, starting with textiles, batteries, and electronics- chain of custody is becoming a regulatory requirement, not just a best practice. In addition, adherence to the EU Green Claims Directive, CSRD, and ESRS helps companies ensure their sustainability statements are auditable and credible.
The digital CoC links:
By integrating all these chains, the digital CoC creates a comprehensive, tamper-proof record that supports Digital Product Passports (DPPs), drives circularity, and enables transparent, accountable supply chains.
The Digital Chain of Custody (CoC) captures every step of the product lifecycle using advanced technologies that ensure accuracy, security, and real-time visibility. Key components include:
By leveraging these tools, the digital CoC ensures that every action, location, and document is accurately recorded, verifiable, and ready for integration into Digital Product Passports (DPPs), enabling full transparency and accountability across the supply chain.
Digital Product Passports require more than static product data; they require verifiable, continuously updated evidence across the full product lifecycle. A robust digital Chain of Custody provides the operational backbone for DPPs by linking materials, processes, actors, locations, and documentation into a single trusted record. Establishing Chain of Custody now enables companies to meet ESPR requirements, EU Battery Regulation, support auditable sustainability and green claims, and scale DPP compliance as additional product categories come into scope.
Sources
Chain of custody - General Terminology and Models
https://www.EU Digital Product Passport Update GS1.pdf
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