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The insights in this article come from ongoing business conversations with brands exploring Digital Product Passports.
What we often see is not resistance, but uncertainty. The regulatory landscape evolves, terminology overlaps, and teams are already managing multiple priorities.
Many decisions to postpone or deprioritise DPP do not stem from lack of interest, but from partial information or unclear framing. When requirements feel abstract or technical, it becomes harder to understand where to start.
This is precisely where clarity makes the difference: Digital Product Passports are not about knowing everything upfront. They are about structuring what already exists, step by step. By addressing the most common assumptions directly, brands can move from uncertainty to informed action, without unnecessary pressure.
One recurring assumption is that companies with lower turnover are excluded from Digital Product Passport requirements. This confusion often arises from mixing up two different EU frameworks:
When a product becomes subject to DPP requirements under the applicable product-specific legislation, the relevant economic operators placing it on the EU market must comply with those requirements. Company turnover does not, by itself, determine whether a DPP is required.
In business conversations, this assumption often appears in different forms:
“We can wait for the delegated act.”
“Legislation may even be postponed.”
All of these reflect the same underlying belief, that there is still time before action becomes necessary.
The EU DPP Registry became operational in July 2026. The European Commission currently indicates Q3-Q4 2027 for the planned adoption of the delegated act for textiles and apparel. Following the adoption of ESPR delegated acts, economic operators will have a transition period of at least 18 months before the corresponding requirements apply.
In parallel to this regulatory timeline, brands require their own operational pathway: perimeter analysis, data mapping, governance setup, system integration, pilot phases, and roll-out. These steps take time and cannot realistically be compressed into the final months before the deadline.
Although the delegated acts detailing product-specific requirements are still pending, the Commission has published an indicative sequence of implementation milestones. Brands already have sufficient clarity to begin structuring their product data and systems.
The regulatory process is advancing, not pausing.
Delaying preparation shortens the implementation window once requirements are confirmed.
Behind these statements lies a practical concern: production moves in stages, and information consolidates progressively. Teams prefer to introduce new systems only once products, suppliers, and documentation are fully defined.
If the QR is linked to the product before production is complete, the impression is that all information must already be final and fixed.
n reality, a QR code can act as the data carrier that provides access to the Digital Product Passport. It can be associated with a product early in the process, even if all information has not yet been finalised. The data connected to the DPP can then be structured, completed and updated over time. Renoon supports this process as product information evolves.
The Digital Product Passport is not a static document created once and closed. It is a structured digital record connected to the product, designed so that authorised data can be maintained and updated throughout the period defined by the applicable legislation.
Most of the required information already exists across sourcing, compliance, and product development. Structuring can begin before every detail is confirmed.
Waiting for “complete” data concentrates implementation in a shorter timeframe.
Another common misunderstanding concerns the technology behind Digital Product Passports.
QR codes, NFC, RFID, and blockchain are often mentioned together, creating confusion about what each tool actually does and how they relate to DPP.
The Digital Product Passport is a digital record of product information required under applicable EU legislation. Technologies such as QR codes, NFC or other data carriers can provide access to it, while other technologies may support the underlying data infrastructure.
QR Code
A scannable data carrier that can provide access to the Digital Product Passport. Depending on the applicable product-specific requirements, the data carrier may be placed on the product itself, its packaging or accompanying documentation. QR codes are widely used because they are easily accessible through smartphones.
NFC
A technology that can provide digital access through a tap. Where compatible with the applicable DPP requirements, it can be used as a data carrier connecting the physical product to digital information.
RFID
A technology widely used for identification, inventory and logistics. Its role in a DPP implementation depends on the applicable requirements and the company's system architecture.
Blockchain
A distributed ledger used to strengthen data integrity. It can support authentication or traceability, but it is not required to implement a Digital Product Passport.
These are infrastructure tools. The DPP is the data system they connect to.
A common concern is that implementing a Digital Product Passport will make supplier relationships publicly visible.
Under the Ecodesign for Sustainable Products Regulation (ESPR), Digital Product Passports follow a decentralised architecture. The EU DPP Registry stores unique identifiers, registration data and required metadata rather than the full product information contained in the DPP. Access to DPP data is differentiated according to the access rights established by the applicable legislation. Not all data is visible to consumers.
This does not mean that all information held within a company's supply chain will become publicly accessible. Which information must be included in the DPP, and who can access it, will be determined by the applicable product-specific requirements.
The system is designed to balance product transparency with the protection of commercially sensitive information.
Brands can structure supplier data for compliance purposes without exposing confidential partnerships or intellectual property.
Renoon supports this by allowing supplier information to remain protected in the backend, while displaying alternative or consumer-facing names where appropriate. This allows companies to manage different information and access layers while adapting the setup to the applicable DPP requirements.
Digital Product Passports do not create complexity. Lack of structured guidance does.
Once the framework is understood, the path becomes operational: define the perimeter, connect existing data, assign identifiers, protect sensitive information, and align internal systems with regulatory milestones.
Renoon supports brands in translating regulatory requirements into structured implementation. Not by adding layers, but by organising what already exists and aligning it with the EU framework.
Starting with structured product data, responsibilities and system readiness can reduce the operational work required once product-specific requirements become applicable.
If you want to assess where you stand and define a clear DPP roadmap, explore Renoon’s advisory services or book a free 1:1 session here.
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