Common Misunderstandings About Digital Product Passports — And Why They Hold Brands Back

The insights in this article come from ongoing business conversations with brands exploring Digital Product Passports.
What we often see is not resistance, but uncertainty. The regulatory landscape evolves, terminology overlaps, and teams are already managing multiple priorities.

Many decisions to postpone or deprioritise DPP do not stem from lack of interest, but from partial information or unclear framing. When requirements feel abstract or technical, it becomes harder to understand where to start.

This is precisely where clarity makes the difference: Passaporti Digitali di Prodotto are not about knowing everything upfront. They are about structuring what already exists, step by step. By addressing the most common assumptions directly, brands can move from uncertainty to informed action, without unnecessary pressure.

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1. “Our turnover is too low for DPP to apply.”

One recurring assumption is that companies with lower turnover are excluded from Digital Product Passport requirements. This confusion often arises from mixing up two different EU frameworks:

• The Corporate Sustainability Reporting Directive (CSRD) establishes reporting obligations based on company size and turnover.
• The Ecodesign for Sustainable Products Regulation (ESPR), under which Digital Product Passports are introduced, regulates products placed on the EU market. It does not link these obligations to company turnover.

When a product category becomes subject to DPP rules, any company placing that product on the market must comply. Turnover determines reporting obligations under CSRD, it does not determine whether DPP applies. As a result, company size does not remove the obligation to comply.

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2. “The timeline is still far away.”

In business conversations, this assumption often appears in different forms:
“We can wait for the delegated act.”
“Legislation may even be postponed.”

All of these reflect the same underlying belief, that there is still time before action becomes necessary.

But Digital Product Passports are introduced under a Regulation in force since 2024. The adoption of the Delegated Act on the Digital Product Passport Registry is scheduled for Q1 2026, with the EU DPP Registry expected to become operational in July 2026. The Delegated Acts for textiles and apparel follow in 2027. From that moment, companies will have a limited transition window - currently indicated at around 18 months - to ensure compliance.

In parallel to this regulatory timeline, brands require their own operational pathway: perimeter analysis, data mapping, governance setup, system integration, pilot phases, and roll-out. These steps take time and cannot realistically be compressed into the final months before the deadline.

Although the delegated acts detailing product-specific requirements are still pending, the sequence of milestones is already defined. Brands have sufficient clarity to begin structuring their product data and systems today.

The regulatory process is advancing, not pausing.

Delaying preparation shortens the implementation window once requirements are confirmed.

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3. “We’ll address DPP later in the process.” “We don’t have all the product data yet.”

Behind these statements lies a practical concern: production moves in stages, and information consolidates progressively. Teams prefer to introduce new systems only once products, suppliers, and documentation are fully defined.

If the QR is linked to the product before production is complete, the impression is that all information must already be final and fixed.

In reality, the QR code is simply a product identifier. It can be associated with a product early in the process, even if not all information has been finalized. The data linked to it can then be structured, completed, and updated over time. Renoon takes care of this process, powered by AI.

The Digital Product Passport is not a fixed document created once and closed. It is a dynamic data layer connected to the product.

Most of the required information already exists across sourcing, compliance, and product development. Structuring can begin before every detail is confirmed.

Waiting for “complete” data concentrates implementation in a shorter timeframe.

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4. “DPP is a technology choice.”

Another common misunderstanding concerns the technology behind Digital Product Passports.

QR codes, NFC, RFID, and blockchain are often mentioned together, creating confusion about what each tool actually does and how they relate to DPP.

The Digital Product Passport is the structured product dataset required under EU regulation. The technologies below are tools that can support it.

QR Code
A scannable code printed on the product. It links the physical item to its Digital Product Passport and is currently the most common access method. Low cost and smartphone-compatible, it enables direct consumer interaction.

NFC
A chip embedded in the product that allows access through a tap. It serves the same function as a QR code, connecting the product to its passport. The difference is technological, not regulatory.

RFID
Primarily used for inventory and logistics. It supports operational traceability but is not typically the consumer access point to a DPP.

Blockchain
A distributed ledger used to strengthen data integrity. It can support authentication or traceability, but it is not required to implement a Digital Product Passport.

These are infrastructure tools. The DPP is the data system they connect to.

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5. “Commercial relationships become public.”

A common concern is that implementing a Digital Product Passport will make supplier relationships publicly visible.

Under the Ecodesign for Sustainable Products Regulation (ESPR), Digital Product Passports require structured product-level information to be made accessible through the EU Registry and related systems. However, access rights are differentiated. Not all data is visible to consumers.

For product groups such as textiles, current EU planning indicates that traceability elements like the country of origin are expected to be included. There is no indication that supplier names must be publicly disclosed.

The system is designed to balance product transparency with the protection of commercially sensitive information.

This means brands can structure supplier data for compliance purposes without exposing confidential partnerships or intellectual property.

Renoon supports this by allowing supplier information to remain protected in the backend, while displaying alternative or vanity names where appropriate. In this way, brands can meet DPP requirements without compromising supplier confidentiality.

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Readiness Beyond Assumptions

Digital Product Passports do not create complexity. Lack of structured guidance does.

Once the framework is understood, the path becomes operational: define the perimeter, connect existing data, assign identifiers, protect sensitive information, and align internal systems with regulatory milestones.

Renoon supports brands in translating regulatory requirements into structured implementation. Not by adding layers, but by organising what already exists and aligning it with the EU framework.

Brands that turn insight into structured readiness will lead the transition.

If you want to assess where you stand and define a clear DPP roadmap, explore Renoon’s advisory services or book a free 1:1 session here.