Digital Product Passports: What Growing Brands Should Do Now

Digital Product Passports are starting to appear in more conversations with manufacturers, retailers and consumer brands. Usually, the first question is fairly simple:

“Do we just need to put a QR code on the product?”

Not quite. A QR code may eventually provide access to a Digital Product Passport, but the code itself is the easy part. The bigger challenge is collecting, checking and maintaining the product information that sits behind it. For many businesses, that information is currently spread across technical files, supplier emails, testing reports, spreadsheets and packaging artwork. Some of it may not have been requested from the manufacturer at all.

That is why Digital Product Passport preparation should not begin with a web developer. It should begin with your product data.

Key takeaway: Digital Product Passport readiness starts with controlled, maintainable product data—not with the QR code.

Who Does This Apply To?

The Digital Product Passport framework is being introduced through the EU’s Ecodesign for Sustainable Products Regulation. It does not mean that every product must immediately carry a Digital Product Passport. Detailed requirements are being developed by product category, with different sectors expected to be brought into scope at different stages. However, the direction of travel is clear.

This is particularly relevant to:

• Fashion and Textile Brands: Clothing and textile businesses are among the sectors receiving early attention under the EU programme.
• Furniture and Mattress Businesses: Brands will increasingly need better visibility of materials, product construction, durability and end-of-life information.
• Electronics and Consumer Product Brands: Businesses already managing technical documentation may need to connect compliance, environmental and supply-chain information more effectively.
• Importers and Private-Label Brands: Importers often rely heavily on overseas suppliers for product data, even though they may have limited control over how that information is recorded.
• Manufacturers Supplying EU Customers: Even where the manufacturer is not based in the EU, European customers may begin requesting more detailed product and material information.

The businesses likely to find this most difficult are not necessarily the smallest. They are the ones with the largest product ranges, the most complicated supplier networks and no central system for controlling product data.

What Does This Mean in Practice?

A Digital Product Passport can be thought of as a structured digital record connected to a product. The exact information required will depend on the product-specific rules. Depending on the category, it could cover areas such as:

• Product identification
• Materials and components
• Recycled content
• Durability
• Repair information
• Care instructions
• Environmental information
• Recycling and disposal
• Relevant compliance documentation
• Manufacturer and supply-chain information

Not every piece of information will necessarily be visible to every person. Some information may be intended for consumers. Other information may be available to regulators, repairers, recyclers or businesses within the supply chain. That distinction matters.

A Digital Product Passport is not simply a public product page containing marketing information. It needs to provide reliable, controlled data that remains connected to the correct product, model or batch. For a brand with five products, that may be manageable. For a brand with 200 products, several manufacturers and frequent product changes, it quickly becomes a much larger project.

Common Mistakes Businesses Make

1. Treating It as a QR-Code Project

This is the most common misunderstanding. A business begins looking at QR-code providers before deciding what information it holds, what information is missing and who is responsible for keeping it accurate. The technology cannot fix poor product data.

It simply makes that data easier to access.

2. Waiting Until the Final Requirements Apply

Some businesses are waiting for every technical detail to be confirmed before doing anything. That may sound sensible, but the early preparation work is useful regardless of the final format. Understanding your products, materials, suppliers and documentation is not wasted effort. It also supports technical files, sustainability claims, packaging obligations and general supply-chain control.

3. Assuming the Manufacturer Has Everything

We see this quite often. The brand assumes its factory already holds complete material, repair, environmental and recycling information. When the questions are eventually asked, the supplier may provide a basic specification sheet or a short declaration that does not contain enough detail.

Finding that out two months before a deadline is very different from finding it out two years earlier.

4. Creating a Passport That Cannot Be Maintained

Product information changes. Materials may be replaced. Suppliers may change. Packaging is updated. Components are discontinued. Test reports are renewed. A Digital Product Passport needs an owner and an update process.

Without that, it risks becoming outdated shortly after launch.

Your Practical DPP Readiness Checklist

Not sure where to begin? Start with the basics.

• Product Prioritisation: Have you identified which product ranges are most likely to be affected first?
• Product Identification: Can you clearly distinguish each SKU, model, version and variation?
• Supplier Information: Do you know which supplier holds the information for every material and component?
• Material Data: Do you have a reliable breakdown of the materials used in the product and packaging?
• Technical Documentation: Are test reports, declarations, specifications and instructions organised in one place?
• Repair and Care Information: Could you explain how the product should be maintained, repaired or safely handled?
• Environmental Claims: Do the claims on your website and packaging match the evidence held within your files?
• Data Ownership: Has someone been made responsible for checking and updating the information?
• Change Control: Would you know when a material, supplier or specification had changed?
• Pilot Product: Have you selected one product to test your approach before applying it across the full range?

You do not need to solve every future DPP requirement today. You do need to know what information you already hold and where the gaps are.

How Conformity Services Can Help

At Conformity Services, we help brands prepare for Digital Product Passports without turning the process into an unnecessarily complicated technology project. We begin with the products. That means reviewing the information already available, identifying missing supplier data and assessing how prepared the business is for future product-information requirements.

Our support can include:

• DPP readiness assessments
• Product and category prioritisation
• Supplier-data gap analysis
• Materials and documentation reviews
• Product-information mapping
• Readiness roadmaps
• Pilot Digital Product Passport preparation
• Wider technical-file and product-compliance support

For some businesses, the right first step is a full portfolio review. For others, it makes more sense to choose one priority product and use it to build a workable process. The aim is not to collect information for the sake of it. It is to create a product-data system the business can actually maintain.

Final Thoughts

Digital Product Passports are often presented as a technology change. For most brands, they will actually be a product-data and supply-chain challenge. The businesses that prepare well will not necessarily be those with the most advanced software. They will be the ones that understand their products, know where their information comes from and have a reliable process for keeping it current.

Starting early does not mean building the final passport today. It means making sure you will have something useful to put in it when the time comes.

Sources and official guidance

This article provides general information, not legal advice. Product-specific Digital Product Passport requirements will depend on measures adopted for the relevant product group.

• European Commission: Ecodesign for Sustainable Products Regulation overview
• EUR-Lex: Regulation (EU) 2024/1781 establishing the ecodesign framework
• European Commission: product standards, tools and labels