Repass

Making Digital Compliance Work for SMEs

Article
28 October, 2025

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As the European Union’s Ecodesign for Sustainable Products Regulation (ESPR) begins to reshape the product landscape, one thing is clear: sustainability is no longer optional. At the center of this shift is the Digital Product Passport (DPP)—a digital record providing transparent information on a product’s materials, lifecycle, and environmental footprint. 
While the vision is ambitious, the reality of implementation is challenging—especially for small and medium-sized enterprises (SMEs). 


The Promise of DPPs 

DPPs aim to reduce waste, improve circularity, and foster accountability across supply chains. By capturing essential product data—from raw material sourcing to end-of-life disposal—they empower consumers, inform regulators, and enable businesses to operate more transparently. 

This level of visibility can drive real progress toward sustainability goals. However, the technical and financial requirements associated with DPPs present significant barriers for smaller businesses. 

The Reality for SMEs 

For many SMEs, the DPP mandate raises concerns around cost, complexity, and capacity. According to the CIRPASS project, which surveyed SMEs across Europe, the most common challenges include: 

  • High implementation costs for software, hardware, and training 
  • Limited internal resources to manage complex data workflows 
  • Unclear regulatory guidance tailored to specific sectors 
  • Dependence on large tech providers, with limited flexibility 

The CIRPASS findings also suggest that many SMEs remain skeptical about the practical benefits of DPP adoption, especially when the return on investment is unclear and the technical burden is high. 

 

The Risk of Digital Inequality 

As large corporations accelerate DPP implementation, they are building proprietary platforms and ecosystems that smaller businesses struggle to access. This creates a growing divide in digital capabilities and market competitiveness. 

The emergence of centralized service providers offering bundled DPP infrastructure—such as QR code generation, data hosting, and compliance tools—can simplify processes for big players but often limits choice for SMEs. These closed systems can create vendor lock-in, leaving SMEs with little control over their own data or the ability to switch providers without significant disruption. 

In some cases, even the QR codes embedded on products may become unusable if the system that generated them is no longer supported. This raises both operational and compliance risks—highlighting the urgent need for open standards and interoperable systems. 

Enabling Inclusive Compliance 

To ensure SMEs are not left behind, the digital tools supporting sustainability must be accessible, flexible, and affordable. Key enablers include: 

  • SME-focused DPP-as-a-Service platforms that are cost-effective and easy to implement 
  • Open standards and interoperability to prevent vendor dependency 
  • Public-private partnerships to fund infrastructure and adoption 
  • Digital skills training to build internal capacity 

Pilot programs and early support will be essential to build momentum and ensure SMEs are ready to meet upcoming regulatory deadlines. 

 

Repass: Making Compliance Work for SMEs 

At Repass, we believe sustainability should be achievable for every business—not just the largest. Our DPP platform is built to scale across industries while remaining cost-effective and adaptable for SMEs, who make up over 99 percent of EU businesses. 

We work closely with smaller companies to ensure that DPPs become a bridge to greater transparency and long-term competitiveness—not a barrier to entry. Our modular, standards-based approach helps SMEs adopt digital tools at their own pace, without locking them into restrictive systems. 

 

The Bigger Picture 

The ESPR and DPP framework represent a major step toward a sustainable future—but one that will only succeed if all businesses can participate. SMEs are the foundation of Europe’s economy and innovation ecosystem. Excluding them from the digital transition is not only inequitable—it is unsustainable. 

Sustainability must be inclusive. Technology must be open. And the future must be built with SMEs at its core. 


Sources: 

Futures Parity: Lars Rensing on the repercussions of Digital Product Passports for businesses. - Protokol 

Bernier - 2023-06-12 EU Webinar CIRPASS | PDF | Information Technology Management | Computing 

CIRPASS-A-study-on-DPP-costs-and-benefits-for-SMEs-v1.0-1.pdf 

Shaping DPP service providers: Building a secure and flexible framework - DIGITALEUROPE 

ESPR’s DPP Mandate for SMEs | SME Today 

Why digital product passports are tailor-made for CX | CX Dive 

IT Channel Take Note: Digital Product Passports Are Coming 

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