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The Ecodesign for Sustainable Products Regulation (ESPR) establishes a single legal framework for Digital Product Passports across product groups placed on the European market. As product-specific delegated acts are introduced, companies covered by those requirements will ultimately need to comply with the same regulatory obligations.
The regulation does not distinguish between SMEs and enterprise organisations.
Implementation, however, rarely follows the same path.
Company size influences the implementation context, but existing data maturity, system complexity and internal organisation often determine how Digital Product Passport projects begin. For this reason, the same regulatory framework often translates into different implementation priorities.
This article explores why SMEs and enterprise organisations often approach Digital Product Passport implementation differently, even though they are preparing for the same European legislation.
The ESPR does not introduce different Digital Product Passport obligations for SMEs and large organisations. Product-specific delegated acts will define the required information, access rights and implementation rules for every company placing the relevant products on the EU market.
The European Commission also makes clear that Digital Product Passport obligations apply to economic operators placing covered products on the EU market, regardless of company size.
What differs is the organisational context in which these requirements are implemented.
Across the Digital Product Passport projects supported by Renoon, enterprise organisations typically begin with product information already distributed across multiple systems, business units and suppliers. SME projects more often begin by identifying existing information, defining priorities and organising responsibilities within smaller teams.
Enterprise organisations rarely need to start by collecting entirely new product information.
In many cases, the required information already exists across PLM, ERP, PIM, supplier platforms, certification systems and internal databases. The challenge is bringing these sources together into a common framework that can support Digital Product Passports consistently across brands, collections and markets.
Typical implementation activities include:
In these projects, organisational coordination often becomes just as important as the technology itself. Rather than creating individual Digital Product Passports, the objective is to establish a repeatable implementation framework that can support future collections and evolving regulatory requirements.
Tod’s provides one example of this approach. Rather than building a Digital Product Passport for a single collection, its project, powered by Renoon, focused on creating a reusable implementation framework by aligning existing product information, defining data ownership and introducing common validation processes. Once this foundation had been established, the same framework could be reused across future collections, significantly reducing the time required to publish new Digital Product Passports. Read the full Tod's case study.
Available in English, Italian version upon request
SMEs often begin from a different position.
Product portfolios are generally smaller and organisational structures less complex, but product information may still be distributed across spreadsheets, supplier documentation and technical files rather than dedicated product information systems.
For many smaller organisations, the first implementation step is therefore understanding which information will actually become necessary before deciding how to organise it.
The methodology recently published by the Joint Research Centre reflects this principle by distinguishing mandatory, strongly recommended and voluntary information while emphasising proportionality when defining Digital Product Passport data requirements.
Rather than building complex infrastructure immediately, SMEs generally benefit from:
Projects with brands such as Dondup illustrate this type of implementation path. Rather than beginning with large-scale system integration, implementation focused on structuring existing product information, progressively involving suppliers and establishing a repeatable process that can evolve alongside future regulatory requirements. Read the Dondup case study.
Available in Italian, English version upon request
These different starting points naturally lead to different implementation priorities.
Enterprise organisations typically focus on governance, interoperability and scalability across existing systems. SMEs are more likely to prioritise identifying the right product information, engaging suppliers progressively and establishing a practical roadmap that can grow over time.
Both are responses to the same legal framework, adapted to different organisational realities. Successful implementation ultimately depends on understanding where product information already exists, who is responsible for it and how it will be maintained over time, regardless of company size.
Regardless of company size, every organisation covered by future ESPR delegated acts will ultimately need to meet the same Digital Product Passport requirements.
The implementation journey, however, will rarely look the same.
Recognising these different starting points allows organisations to prepare proportionately, avoiding unnecessary complexity while building the product data foundations that future Digital Product Passports will require.
Whether your organisation is preparing its first Digital Product Passport or scaling implementation across thousands of products, the first decisions are rarely the same.
Explore our dedicated implementation guides for SMEs and enterprise organisations, or get in touch to discuss which approach best fits your organisation.
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