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Product transparency is now a structural feature of the European market. Regulations such as the Ecodesign for Sustainable Products Regulation (ESPR) and the introduction of Digital Product Passports define how certain product information must be documented, structured, and made accessible.
Within this framework, companies face a practical challenge: understanding which information should actually be disclosed, to whom, and for what purpose.
Transparency does not mean publishing every piece of product information associated with a product.
This is where the concept of right-sized transparency becomes relevant. The goal is not to share more data, but to share the right product information in the right context.
Transparency is not about sharing more information. It is about sharing the right information.
Product Information Has Different Aims
Questions about product transparency do not start with the Digital Product Passport. Companies already manage large volumes of product data across sourcing, compliance, and product development.
What the DPP does is make this challenge more visible: once information is structured at product level, companies must clarify which data must be disclosed under regulation and which data serves internal or operational functions.
For example, some information is required to demonstrate regulatory compliance, such as product characteristics, materials, or origin elements defined by EU legislation. Other information exists to manage production, coordinate suppliers, or document technical specifications.
These datasets often sit next to each other inside company systems, but they do not serve the same purpose.
Transparency therefore requires understanding which data must be disclosed, in which context, and for which regulatory or communication objective.
Regulatory Disclosure and Voluntary Communication
In product transparency, it is important to distinguish between regulatory disclosure and voluntary product communication.
European product regulation does not require companies to disclose every piece of information associated with a product. Instead, it defines specific categories of product data that must be structured and made accessible.
For example, under the Ecodesign for Sustainable Products Regulation (ESPR), product-specific rules can require certain information to be documented and made available through the Digital Product Passport, such as product characteristics, material composition, durability parameters, or repairability indicators depending on the product category.
Importantly, the Digital Product Passport is not designed as a fully public dataset. The regulation foresees different levels of access depending on the type of user, allowing regulators, economic operators, and consumers to access different layers of information while protecting commercially sensitive data.
In practice, this means that some information forms part of regulatory product data, while other information remains part of product communication. For instance, a Digital Product Passport may include structured information such as material composition or care instructions defined by product rules, while elements such as brand narratives or sustainability storytelling remain voluntary.
The DPP framework also distinguishes between different types of product data. Some information is static, such as material composition or product identifiers, while other data can be dynamic, such as repair history or lifecycle updates.
Understanding these distinctions helps clarify a key point: transparency depends on structuring the right information for the right purpose, not publishing every dataset associated with a product.
When Transparency Becomes Counterproductive
Sharing more information does not always improve transparency. In some cases, excessive disclosure can create new risks.
One concern is the exposure of commercially sensitive information. Supply chains often contain strategic relationships, sourcing structures, and operational practices that companies are not required to disclose publicly. Making these datasets visible without a clear purpose can weaken competitive positioning without improving product understanding.
Another risk is misinterpretation of technical data. Internal product documentation often includes laboratory test parameters, production specifications, or compliance documentation designed for engineers, suppliers, or auditors. When this information is disclosed without context, it can be difficult for non-technical audiences to interpret correctly.
There is also a practical issue of information overload. If product transparency simply means attaching large quantities of documentation to every product, the result is not greater clarity but greater complexity.
This is precisely why the concept of right-sized transparency is gaining attention. The objective is not to disclose less information, but to ensure that the information attached to products is relevant, structured, and meaningful for its intended use.
From Disclosure to Data Governance
If transparency is treated only as disclosure, it quickly reaches its limits.
Modern products generate large amounts of information across sourcing, testing, compliance, and product development. Much of this data already exists inside companies, but it rarely travels with the product itself.
The challenge is therefore not only deciding what information should be shared, but ensuring that product data is structured and connected to the product over time.
Without systems that organise this information, transparency remains fragmented across internal documentation, supplier systems, certifications, and marketing communication.
The Digital Product Passport reflects this shift. Rather than asking companies to publish more information, it introduces a framework where product data is structured, governed, and linked directly to individual products.
Transparency therefore moves from disclosure to data governance, where different datasets serve different purposes and access depends on context.
Right-sized transparency does not start with the question:
“What should we publish?”
It starts with a different one:
How should product information be structured so that it remains useful, reliable, and accessible across the product lifecycle?
At Renoon, we support companies in structuring product and supply chain data into Digital Product Passports, helping translate regulatory requirements into operational systems.
Explore our advisory services or book a demo to assess your readiness for Digital Product Passports.
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