Understanding the Barrier to DPP Readiness

Article

14 April, 2026

When people talk about Digital Product Passports (DPPs), the discussion usually focuses on compliance: what the EU requires, what data to collect, and which systems to use. But this view only scratches the surface. The Ecodesign for Sustainable Products Regulation (ESPR) is clear about the goals—better sustainability information, stronger market oversight, and digital access to product data. It also leaves technology choices open, meaning brands are free to use cloud systems, APIs, or global standards like GS1.

Because of this flexibility, the main barrier is not the regulation itself. The real challenge is access: the ability of thousands of small and medium‑sized suppliers to join a more digital, data‑driven supply chain. Compliance is a visible surface; access is an underlying structural issue.

Symptoms Are Not the Cause

Many brands preparing for DPPs encounter the same recurring problems:

Product data is fragmented
Suppliers use different file formats
Many factories rely on manual spreadsheets
Older ERP or PLM systems cannot easily send or receive structured data

These are all real challenges, especially in textile supply chains, which are known for being highly fragmented and full of small actors. Studies show that digital maturity in this sector is uneven, making standardised data collection difficult.

But these issues are symptoms. The deeper cause is that most suppliers simply don’t have the digital capacity to participate. SMEs make up more than 99% of all EU enterprises, including many fashion suppliers. If they cannot join the DPP ecosystem, brands cannot achieve the transparency that the regulation expects.

Why Access Matters More Than Technology Choices

The EU has deliberately made ESPR and the DPP system technology‑neutral. Companies can use many different solutions if they meet requirements for interoperability, security, and reliable data.

In theory, this should make compliance easier. In practice, it creates a different challenge: the market decides which technologies and workflows suppliers must adopt.

If brands use proprietary QR systems, closed data models, or solutions that require heavy IT integration, smaller suppliers will struggle. GS1 warns that without shared, global standards like GTINs, Digital Link, and EPCIS, DPPs become inconsistent and expensive to scale.

This uneven access becomes a structural problem: a few large suppliers can meet requirements, while the long tail of smaller manufacturers cannot.

Supplier “Resistance” Is Usually a Capacity Problem

It’s easy to assume that suppliers are slow to respond, don’t prioritise DPP, or don’t want to share data. But research on SME digitalisation shows a different picture. Small companies often struggle with:

Limited budgets
Shortage of digital skills
Outdated systems
Limited awareness of technology providers
High cybersecurity requirements
Tight margins and limited time for training

These issues have been documented across Europe in OECD and academic research.

In textile supply chains, these pressures are even stronger. Many factories operate with thin margins, basic digital tools, and inconsistent data formats. They need solutions that lower the barrier, not raise it.

What “Access” Should Look Like

If access is the real problem, then the solution must focus on lowering barriers for suppliers. This doesn’t mean giving up traceability or quality data. It means choosing tools and workflows that match the reality of global supply chains.

Better access means:

1. Easy-to-use digital tools

Suppliers need simple onboarding, guided templates, and cloud portals that don’t require IT teams. This is especially important in textiles, where many businesses are small.

2. Open and global standards

Using GS1 standards (GTINs, Digital Link, EPCIS) reduces friction and ensures data flows consistently across borders and systems.

3. Fewer proprietary systems

Avoiding closed, vendor‑specific platforms prevents lock‑in and makes life easier for suppliers who already juggle multiple customer requirements.

4. A realistic rollout path

Starting with one product category or a data‑rich part of the business makes the transition manageable.

5. Support and training

Many suppliers simply lack the knowledge to participate. Training, guidance, and clear expectations are essential.

Why This Matters for Competitiveness

DPPs are becoming a condition for entering the EU market. Delegated acts will define details of product by product, and textiles are among the first categories on the roadmap.

If suppliers can’t participate, brands won’t have the data they need. This affects:

Market access
Customer trust
Sustainability claims
Circularity strategies
Long‑term competitiveness

Brands that help their suppliers succeed will gain stronger data, smoother compliance, and more resilient supply chains. Those that ignore supplier capacity may face delays, disruptions, or incomplete DPPs.

Conclusion

The biggest challenge in DPP is not the regulation itself. It is the ability of suppliers—especially SMEs—to participate effectively in a digital, transparent system.

By focusing on access, not just compliance, brands can: