Digital Product Passport for SMEs: what small brands really need to do

Yes, the obligation applies to you too - but no need to panic

First the uncomfortable truth: the DPP obligation is tied to placing products on the EU market, not to revenue or headcount. A three-person brand selling e-bike batteries or apparel is just as affected as a large corporation. There is no general SME exemption from the product passport.

Now some perspective: the EU knows that SMEs do not have compliance departments. The ESPR expressly provides support measures for SMEs, and for individual obligations there are reliefs - with the ban on destroying unsold textiles, for example, small companies are exempt and medium-sized ones are not affected until 2030. Above all: the product passport itself is implemented considerably faster for a small range than for a corporate catalogue with tens of thousands of articles. Being small is an advantage here.

What is coming for SMEs - and what is not

This is coming:

• One machine-readable product passport per article, with materials, origin, evidence and circular-economy information (what exactly is in the DPP guide)
• A QR code on the product or label as a data carrier
• A maintenance process: the passport must stay current when material, supplier or certificate changes

This is not coming:

• No obligation to build your own system - the passport may be provided via a service provider/software
• No requirement for expensive certifications beyond the product requirements that already apply
• No single key date “for everyone”: your deadline depends on your product group (all deadlines at a glance)

The 5-step roadmap for small teams

1. Determine your deadline (1 hour). Which of your product groups falls under which regulation? E-bike batteries: 18/02/2027. Textiles and tires: expected 2027/2028. Furniture: 2028, mattresses: 2029, toys: around 2030. From there, count back 12-18 months - that is your starting point.
2. Take a data inventory (1 day). What already exists - in the shop system, in supplier documents, on labels? The gaps (almost always: origin details, material percentages, certificate validity periods) become your task list.
3. Ask suppliers early (concurrently). The classic: you wait weeks for origin and material evidence. Requested early and in bulk, this runs in the background; under time pressure it becomes a bottleneck. This is the biggest cost lever in the entire project (to the cost calculation).
4. Maintain base articles instead of variants. 200 articles are often just 40 base products with colour and size variants. Capture the base, derive the variants - this reduces the effort by a factor of three to five.
5. Publish and assign responsibility (1 afternoon). Put DPP pages live, add QR codes to your next label/packaging order, and decide who will maintain changes going forward.

Why SMEs benefit twice from an early start

For D2C brands the product passport is not only an obligation but marketing with substance: origin and material transparency directly on the product visibly sets a small brand apart from anonymous mass-produced goods - as shown in our annotated practical example of the Vienna-based brand Soda Lingerie. Those who publish early use the obligation as a showcase instead of chasing after it.

SolveDPP’s DPP software is built precisely for this scenario: Shopify import instead of re-entry, AI pre-fill of recurring fields, validation against the mandatory data of your regulation, and hosted DPP pages including a QR code - at prices that are predictable for small teams.