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Digital Product Passport requirements are becoming more specific through delegated acts, Registry infrastructure, and interoperability rules.
As a result, fashion brands are starting to face operational questions around product-level data structure, supplier-linked information, lifecycle persistence, Registry integration, long-term accessibility of DPP data.
This is changing what companies should expect from DPP solutions in 2026.
A DPP solution should support product data at:
depending on how future delegated acts define requirements.
A DPP provider should allow brands to connect:
to the correct product record.
EU source: JRC DPP Requirements Methodology (2026)
A DPP solution should help brands manage operational requirements linked to the future EU Registry, including:
EU source: Draft DPP Registry Implementing Regulation (2026)
A DPP solution should allow brands to attach supplier-linked information directly to:
This can include:
The system should also support updates when sourcing conditions or suppliers change.
EU source: ESPR Regulation (EU) 2024/1781
Product information used for Digital Product Passports is often distributed across:
A DPP solution should support the ability to connect and structure information coming from multiple systems and formats.
EU source: JRC DPP Requirements Methodology (2026)
A DPP solution should support:
Registry drafts already introduce expectations around persistence and continuity of DPP records, with a default 10-year accessibility period unless otherwise specified for a product category.
EU source: Draft DPP Registry Implementing Regulation (2026)
Different delegated acts will introduce different requirements depending on the product category.
A DPP solution should therefore support:
without requiring brands to rebuild the entire DPP structure each time requirements evolve.
EU source: ESPR Working Plan 2025–2030
The DPP framework distinguishes between different categories of actors interacting with product information, including consumers, authorities, manufacturers, customs authorities, and other relevant operators.
A DPP solution should therefore support the possibility to manage different levels of visibility depending on:
For example, brands may choose to display a supplier vanity name on the consumer-facing DPP while maintaining more detailed supplier records internally or for authorised access only.
Not all DPP information is necessarily intended to be publicly accessible in the same way.
EU source: ESPR Regulation (EU) 2024/1781
A DPP solution should help brands structure information in formats compatible with:
Responsibility for the information itself remains with the economic operator placing the product on the market.
EU source: Draft DPP Registry Implementing Regulation (2026)
A DPP solution should give brands clarity around:
EU source: European Commission consultation on DPP service providers (2024)
A DPP solution should support the possibility to maintain or add information linked to the product after the initial transaction.
This can include:
EU source: ESPR Regulation (EU) 2024/1781 and Draft DPP Registry Implementing Regulation (2026)
Digital Product Passport requirements are becoming increasingly detailed through delegated acts, Registry drafts, interoperability rules, and service provider requirements.
For fashion brands, this means evaluating DPP solutions not only on the final product experience, but on their ability to support structured product data, Registry-related requirements, supplier-linked information, and long-term accessibility over time.
At Renoon, we continuously monitor these developments through our DPP regulatory newstracker and work directly with brands to translate evolving EU requirements into operational DPP structures.
If you want to understand how these requirements apply to your products and systems, feel free to get in touch with our team.
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