The regulation is the deadline.
The data is the opportunity.
ESPR makes a Digital Product Passport mandatory. Treating it as a compliance exercise buys you a certificate. Treating it as product infrastructure buys you the first reliable view of what you make, where it goes and what it is worth after the first sale.
The clock is already running
The Ecodesign for Sustainable Products Regulation is in force, and the requirements arrive in sequence rather than all at once. Two of these four have already landed.
- July 2024In force
The Ecodesign for Sustainable Products Regulation entered into force
- July 2026In force
Ban on the destruction of unsold apparel, footwear and accessories, plus mandatory reporting
- Feb 2027Next
Standardised disclosure requirements apply
- ~2028
Digital Product Passports become mandatory for these categories
Impacted categoriesApparel · Footwear · Accessories
This is not a reporting exercise. It is a structural change to how products are designed, tracked and sold.
The questions every brand is asking
Nobody arrives at this having decided what to do. They arrive with these five, in roughly this order.
- Is my brand actually impacted?
- How far behind am I?
- What do I really need to build?
- Will my DPP create value for my clients?
- Where do I start?
Most brands are still treating DPP as a compliance project.
It is, in reality, a transformation of their product architecture.
If those five questions are still open, the challenge is no longer awareness. It is execution.
Where brands get stuck
Three failure modes, and a programme usually has more than one of them at the same time.
Compliance owns it
The passport is scoped as a legal deliverable, so it is built to satisfy an auditor rather than to be used by anyone else in the business.
The data is not there
Product data lives across PLM, ERP, suppliers and spreadsheets, at different levels of granularity, and no one system can answer for a single item.
No one owns the value
Resale, repair, authentication and client relationships all depend on the same identifier, and none of them have a budget line for it.
How the work runs and what it has been run on before are each a page of their own.
Find out where you actually stand
Nine questions is usually enough to tell whether the problem in front of you is compliance, data, or ownership — and which of the three to solve first. Free, three minutes, no sign-up to see your score.