Digital Product Passport Compliance: It’s Not What You Think

Many brands think they’re DPP-ready. But are they?

Fashion brands and retailers supplying into the EU know they need to prepare for Digital Product Passports (DPPs) It’s a major priority for Compliance, Sustainability, Design, Sourcing and Technology teams.

Yet, when asked how teams are preparing, the answer often comes:

“We are planning a QR code on our care labels that links to a webpage with the product specifications.”

But here are the real questions that are not being answered:

Where are you getting your data from?
Can you evidence those product specifications and green claims? 
Can you automate the capture of missing data per product line?

That’s usually where confidence disappears.

Because when brands are asked where the supporting data actually lives, the answer is potentially, “We don’t have it.” Or, “It’s in spreadsheets, supplier records, BOMs and invoices.”

And that is precisely the problem. 

When data is not collated, categorised and validated in a systematic, coherent and usable way, it falls over very quickly. 

The risk is that Digital Product Passports will not be complete or at all reliable. They may even open up brands and retailers to accusations of green washing, or penalties for non-compliance.

Digital Product Passports cannot be seen as a simple software requirement. They are not just a QR code on a wash label which links to a website. They present a complex data challenge that requires a systematic approach to how companies capture, verify and maintain records on their supply chain and product lines.

Let’s re-frame: what a Digital Product Passport (DPP) is really 

Digital Product Passports (DPPs) form part of the EU’s EcoDesign for Sustainable Product Regulation (ESPR) which went into force on 18 July 2024.

Importantly, ESPR legislation stipulates that businesses selling into the EU must be able to identify and action risks present in their supply chain, as well as presenting data in a DPP.

A DPP is a digital record which will display detailed information about a product's environmental credentials throughout its entire lifecycle. It should include data on the product and its supply chain, offering insights into the materials used, manufacturing processes, care, reuse and recycle options and overall sustainability.

The DPP should be made accessible to the consumer on a webpage. This should be available via a unique ID (like a QR code on a wash label, or an RFID tag embedded in a product) and available to view for the lifespan of the product.

The EU is currently finalising the Delegated Acts that will detail exactly what data will be required as part of a phased deployment (currently expected from 2027 onwards).

In addition to displaying the required data, businesses will also be expected to hold the supporting evidence that validates the information included in the Digital Product Passport.

Non-compliance will impact market access to the EU and may result in civil penalties.

Digital Product Passport Compliance is more than displaying data

From a consumer perspective, and for some brands, a DPP has been simplified to: 

• A QR code on a product label
• Product traceability
• Sustainability credentials
• End-of-life or recycling instructions

• Discovering and mapping upstream suppliers and locations
• Tracing products across multi-tier supply chains
• Collecting environmental and operational supplier data
• Validating that data against trusted third-party sources
• Identifying risks and inaccuracies before publication
• \Maintaining evidence to support every environmental claim being made.

This type of end-to-end DPP will not only be a powerful way for brands to showcase their sustainability credentials, it will also be able to substantiate those claims with accurate, verifiable data. Furthermore, an end-to-end DPP also will enable brands to identify and mitigate supply chain risk, which is a key requirement of the ESPR legislation.

Without the ability to substantiate the information presented, brands risk being accused of greenwashing and could even face fines for failing to comply with DPP requirements and other related legislation.

A product DPP will be a window for the consumer into your supply chain

A product DPP will paint a picture of sourcing practices and design decisions made by the fashion brand or retailer, whether good or bad.

Therefore, Digital Product Passports will have ramifications for decision-making at the design phase, such as which materials to choose, organic, recycled or sustainable options, and thinking ahead to recyclability and re-use. 

DPPs will influence sourcing decisions as well, teams should be considering suppliers’ green credentials, for example, e.g. looking for manufacturers with regenerative energy supplies or closed-loop water systems. 

Forward-thinking brands will see that DPP platforms must be part of a broader transparency strategy, one that supports environmental goals, risk management, strong governance and compliance, as well as marketing and future growth.

The solution brands choose today must support their needs over the next three to five years as legislative requirements evolve, as internal business operations change and as product lines come and go. Therefore a DPP solution must be holistic, that includes end-to-end data collection, mapping and validation, through to automatically updating products DPP as they change. 

If you don’t think end-to-end, you will end up with a technology or marketing-led solution that will bring limited value, and introduce reputational risk.

The Data Brands Need to Capture

To publish a compliant and credible Digital Product Passport (DPP), brands need far more than product descriptions and sustainability marketing claims. They need access to structured, validated, and traceable supply chain data that can withstand regulatory scrutiny.

This starts with the discovery and mapping of upstream suppliers, giving brands visibility of every supplier location involved in producing and delivering their products across Tier 1 to Tier 4 suppliers.

Brands must also establish full product traceability and collect detailed environmental and operational data relating to both suppliers and products. This includes information such as:

• manufacturing processes,
• product composition,
• material weights,
• recycled content,
• hazardous materials data,
• certificates and test reports,
• recyclability and durability information,
• care and repair instructions,
• disassembly guidance,
• environmental footprint data, 
• and product registration within DPP registries.

Crucially, this data must be validated against trusted third-party data sources to reduce risk before information is published.

This is where many organisations discover they are nowhere near as prepared as they initially believed. In practice, the data needed to support DPP requirements is often scattered across multiple spreadsheets, internal systems, and supplier documents that are not regularly updated, validated, or connected. While the data may technically exist, it is frequently inconsistent, difficult to trace back to source systems, and not structured in a way that supports compliance or audit requirements.

DPP Compliance Risks: Fines, Greenwashing Claims and Reputational Damage

Brands need to be aware that their DPP communications involve publishing environmental product credentials directly to regulators, retailers, investors and consumers at scale.

If these credentials are not supported by robust evidence and reliable data, brands leave themselves open to accusations of greenwashing, which can cause significant reputational damage. Additionally, failing to substantiate environmental claims could also place businesses in breach of legislation, potentially resulting in substantial financial penalties.

For example, under UK and EU Green Claims Code legislation, environmental claims must be backed by credible evidence and verifiable data. Potential penalties for non-compliance can be severe. Fines can reach up to 10% of global annual turnover in some cases.

Failure to meet legislative requirements, including those linked to the DPP, can trigger a range of negative consequences beyond financial penalties. Brands may face regulatory investigations, declining consumer trust, reduced sales performance, and even damage to company valuation and share price.

How Segura’s approach to Digital Product Passports is different

This is where Segura can play a critical role for your business. Segura’s solution helps brands move beyond surface-level DPP readiness by ensuring that product and supply chain data is:

• Captured at source across multi-tier supply chains
• Validated and standardised for consistency and accuracy
• Structured for compliance with evolving DPP requirements
• Traceable and auditable to support regulatory scrutiny
• Continuously maintained as supply chains evolve

When companies have visibility, validation and control over their manufacturing supply chain, Segura's Digital Product Passport allows consumers to view their products' sustainable, environmental and ethical credentials.

DPP Use Cases: An End-to-End Solution That Protects Your Brand

With Segura’s DPP, a unique QR code can be generated and shared with your care label manufacturers and automatically associated with the product data captured in the Segura system. Retailers also select the relevant data they have collected to display in the product DPP.

In practice a DPP solution must also stay abreast with your product ranges, as new product lines are introduced, old products taken off sale, or improvements made to existing designs. Let’s look at some examples.

What if your product changes?

For example, you review your underwear range and decide to switch to verified sustainable cotton. The improved product is in every other way the same. But you need to make sure that your product DPP is revised. The Segura end-to-end DPP will pick up this change to the material composition automatically via the Purchase Order, and update what is published in your DPP.

What if your supplier changes?

For example, you decide to switch your viscose manufacturer to one that is FSC certified. Again, this means you need a revised DPP to reflect the new supplier and location, even though the product design isn’t changing in any other way. Segura’s end-to-end DPP solution would reflect the changing supplier in the DPP and automatically update it into a new version.

What if your product is no longer for sale?

For example, you retire a product line at the end of the season and remove it from your eCommerce store. However, you still need to keep a DPP online for customers to check. The QR code and product data will remain intact with the Segura system and the separate DPP page kept online.

Segura’s software enables brands to build a trusted data foundation for Digital Product Passports so you no longer have to rely on disconnected spreadsheets and assumptions.

It also gives retailers the opportunity to promote all the good work they are doing to deliver sustainable products from ethical suppliers and support the customer in their buying decisions.