---
title: "Digital Product Passport Compliance: It’s Not What You Think"
description: Think you're DPP-ready? Learn why Digital Product Passport compliance depends on supply chain visibility and validated data, not just a QR code.
image: https://www.segura.co.uk/hubfs/dppcomplianceareyouready.png
---

[![segura_landscape_logo-1](https://www.segura.co.uk/hs-fs/hubfs/segura_landscape_logo-1.png?width=2137&height=685&name=segura_landscape_logo-1.png "segura_landscape_logo-1")](https://www.segura.co.uk/)

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

- ** Written by Ed Austin
- ** Published on 10 June 2026
- [**Blogs](https://www.segura.co.uk/resources/press/tag/blogs) [**Digital Product Passport](https://www.segura.co.uk/resources/press/tag/digital-product-passport) [**FAQs](https://www.segura.co.uk/resources/press/tag/faqs) [**Legislation Compliance](https://www.segura.co.uk/resources/press/tag/legislation-compliance)

 

![digitalproductpassportphone](https://www.segura.co.uk/hs-fs/hubfs/digitalproductpassportphone.png?width=327&height=648&name=digitalproductpassportphone.png)

## 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) ](https://www.segura.co.uk/resources/press/digital-product-passport-what-you-need-to-know)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.

### Key Takeaways

[Let's reframe: What a Digital Product Passport (DPP) is really ](https://www.segura.co.uk/resources/press/digital-product-passport-compliance-its-not-what-you-think#JRC)

[Digital Product Passport compliance is more than displaying data](https://www.segura.co.uk/resources/press/digital-product-passport-compliance-its-not-what-you-think#step1)

[A product DPP will be a window for the consumer into your supply chai](https://www.segura.co.uk/resources/press/digital-product-passport-compliance-its-not-what-you-think#step2)n

[The data brands need to capture](https://www.segura.co.uk/resources/press/digital-product-passport-compliance-its-not-what-you-think#step3)

[DPP compliance risks: fines, greenwashing claims and reputational damage](https://www.segura.co.uk/resources/press/digital-product-passport-compliance-its-not-what-you-think#end-to-end)

[How Segura’s approach to Digital Product Passports is different](https://www.segura.co.uk/resources/press/digital-product-passport-compliance-its-not-what-you-think#faq) 

[DPP Use Cases: An end-to-end solution that protects your brand](https://www.segura.co.uk/resources/press/digital-product-passport-compliance-its-not-what-you-think#Why)

 

## 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)](https://inbound.segura.co.uk/espr-dpp-factsheet) 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).

![DPPcomplianceactionsteps](https://www.segura.co.uk/hs-fs/hubfs/DPPcomplianceactionsteps.png?width=800&height=147&name=DPPcomplianceactionsteps.png)

**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

![Iceberg DPP](https://www.segura.co.uk/hs-fs/hubfs/Iceberg%20DPP.png?width=680&height=1048&name=Iceberg%20DPP.png)  
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

 Consumers will see these things. Yet, what consumers see is only the final layer of a much larger data infrastructure challenge. A true end-to-end DPP requires brands to build an entirely new level of visibility and control across their supply chains.

That means:

- 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](https://www.segura.co.uk/resources/press/eu-uk-greenwashing-rules-what-retailers-need-to-know-in-2026) 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](https://www.segura.co.uk/resources/press/the-supply-chain-mapping-process-a-step-by-step-guide), 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 ](https://www.segura.co.uk/resources/press/supply-chain-traceability-fashion)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](https://greenclaims.campaign.gov.uk/) and [EU Green Claims Code legislation](https://environment.ec.europa.eu/topics/circular-economy-topics/green-claims_en), 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](https://www.segura.co.uk/solutions/modules) 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](https://www.segura.co.uk/solutions/modules/seguras-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](https://www.segura.co.uk/solutions/modules/seguras-digital-product-passport), 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.

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```json
{
  "@context": "https://schema.org",
  "@type": "FAQPage",
  "mainEntity": [{
    "@type": "Question",
    "name": "What is the biggest challenge of DPP compliance for fashion and textile brands?",
    "acceptedAnswer": {
      "@type": "Answer",
      "text": "At present, we would suggest there are two major challenges.

Firstly, we don’t yet know the exact data collection requirements from the European Union, or a proven recommended solution from the Cirpass2 project, which is tasked with prototyping solutions. So, we are planning on robust assumptions.

Secondly, one of the biggest hurdles is the sheer volume and complexity of data required to meet anticipated DPP standards. This level of supply chain transparency has rarely been demanded before, and many suppliers are not yet accustomed to providing such detailed information.

That’s where Segura’s solutions come in. We’re already seeing 30–40% supplier crossover between different brands—and that number continues to grow. This enables a quicker on-boarding process for your suppliers as many are already familiar with our platform. Segura enables you to efficiently gather, validate, and structure the data you need, and our digital product passport module is easy to share with consumers in a clear, accessible format."
    }
  },{
    "@type": "Question",
    "name": "Are there any benefits of the DPP for fashion retailers and brands?",
    "acceptedAnswer": {
      "@type": "Answer",
      "text": "Yes, while the Digital Product Passport for textiles is a regulatory requirement, it also brings significant commercial and strategic benefits for retailers and brands. By capturing and sharing transparent product data, brands can:

    Build consumer trust through verified sustainability and sourcing claims
    Differentiate products with credible credentials around materials, ethics, and environmental impact
    Enhance brand storytelling by making supply chains visible and values-driven
    Streamline compliance and reporting across environmental and social governance (ESG) frameworks
    Strengthen supplier relationships by creating a more collaborative and accountable ecosystem
    Support circular economy goals by providing care, repair, and recycling information that extends product life

In short, the DPP isn’t just about compliance, it’s an opportunity to future-proof your brand, improve operational transparency, and deliver value across product design, buying & sourcing, CSR, marketing, eCommerce, risk, finance and legal teams."
    }
  },{
    "@type": "Question",
    "name": "Will the EU stick to its published timelines? Or will it be pushed back again?",
    "acceptedAnswer": {
      "@type": "Answer",
      "text": "At present the EU is sticking to the DPP timelines that we’ve outlined here. We are now little more than 6 months away from the time set for adoption of new legislation by the EU Commission, yet we do not have a scheduled date yet for the draft legislation in Q3/4. A working plan with more detail of the scope was published in April 2025, otherwise we wait to see if there will be any changes."
    }
  },{
    "@type": "Question",
    "name": "How long will it take us to set up a Digital Product Passport software solution?",
    "acceptedAnswer": {
      "@type": "Answer",
      "text": "A DPP software on its own is like having a roof to a house. Without the foundations and walls it won’t be of any use. First you need the foundations, which is your supplier data and then the walls, your product data. When you have both, then you can implement a software solution. Here are our recommended timelines for the whole process:

Duration (est.)	Tasks to reach a compliant Digital Product Passport solution
3-6 months	Identify and select a supply chain mapping platform, set out your requirements and create a phased deployment plan aligned to your legislative requirements, targets and commitments.
1-6 months	Discover and map your upstream supply chain; the size of your business can effect your timescales.
Ongoing	Collect product data, ESG data and evidence whilst uncovering risks; Gap analysis will be simpler  through reporting, however ongoing management and supplier engagement is key to success.
Ongoing	Take action to mitigate risks; through a platform you will be able to identify risks, but this will require ongoing reviews and focus.
3-9 months	Move forward with a DPP solution, timescales will be dependant on your desired approach but shouldn't be under-estimated — engage your internal teams now and plan those activities."
    }
  },{
    "@type": "Question",
    "name": "Will the DPP for textiles require a QR code?",
    "acceptedAnswer": {
      "@type": "Answer",
      "text": "The exact type of data carrier required for the Digital Product Passport (DPP) is still being finalised. While options such as NFC tags and barcodes are also being considered, QR codes are currently a widely used method for accessing digital product information in-store or elsewhere using smartphones.

Although not mandatory at this stage, QR codes offer a practical and familiar way for consumers to scan and instantly view details about a product’s origin, lifecycle, and sustainability credentials, making them a popular choice for many existing DPP implementations."
    }
  },{
    "@type": "Question",
    "name": "How are we going to label footwear, e.g. sandals or high heels with an appropriate DPP?",
    "acceptedAnswer": {
      "@type": "Answer",
      "text": "This is going to come out in the wash (excuse the pun!) We believe it’s likely that a DPP label / QR code will have to be present on the shoe box, or any labels attached to the shoe, rather than being on the product itself. We assume that we may hear more details from the pilots in the Cirpass2 project or once the legislation is drafted."
    }
  },{
    "@type": "Question",
    "name": "How are we going to ensure that the QR code on a label will last the lifetime of a garment?",
    "acceptedAnswer": {
      "@type": "Answer",
      "text": "There are variables and unknowns here too. 

Will there be a methodology of estimating the lifespan of an item?
How can retailers know the frequency or use, or wear than an item is likely to undergo?
Will they assume a certain number of wash-cycles for an item of clothing and test to see if a QR code printed on a label can be used successfully at that stage? 
Conversely, if an item of clothing is barely worn after 10 years, and the owner wants to dispose of it, will the ‘end of use’ information still be live and online at that stage?
Similarly, what happens if a retailer goes out of business? Will consumers be able to access information then? (See the DPP registry below.)

And there are other questions. For example, will the need to make care labels last longer mean that retailers adopt more plastic into labels, which leads to a less circular design?

And what about footwear? If shoes have care labels underneath the tongue, then this is often rubbed off (especially by children or those who don't like wearing socks!)

In short, there are a lot of unanswered questions about how to make DPPs on products workable in real use-cases."
    }
  },{
    "@type": "Question",
    "name": "What is the European DPP registry?",
    "acceptedAnswer": {
      "@type": "Answer",
      "text": "The EU framework for the Ecodesign for Sustainable Products requirements sets out that the EU Commission should “have direct access to a record of all unique identifiers linked to products placed on the market” and therefore should “set up and manage a digital product passport registry to store such data”. The registry would be to enable authorities to enforce EU law and manage risk e.g. Customs checks."
    }
  },{
    "@type": "Question",
    "name": "What do retailers have to do with the DPP registry?",
    "acceptedAnswer": {
      "@type": "Answer",
      "text": "Retailers would have to upload their DPP data and keep it up-to-date. Although we do not know the format yet, Segura will ensure there will be functionality to upload from Segura into the EU registry."
    }
  },{
    "@type": "Question",
    "name": "Will consumers have access to the DPP registry?",
    "acceptedAnswer": {
      "@type": "Answer",
      "text": "At this point, we don’t think so, as its purpose is to help authorities run checks and monitor risks. Also we don’t know yet what data will be required for upload or what will be published and shared. However, there may be benefits to consumers if a general DPP registry were searchable, especially if businesses close and items are still in use. Could you run your ‘end of life’ search there instead of with the retailer?"
    }
  },{
    "@type": "Question",
    "name": "We use a Product Lifecycle Management (PLM) software. Could that be used to power a DPP solution?",
    "acceptedAnswer": {
      "@type": "Answer",
      "text": "A PLM is not designed to accurately reflect the supply chain; it's a planning tool that supports Product Design and Sourcing, helping teams make informed and strategic decisions about component materials, product composition and environmental impacts. A PLM can be a powerful tool when considering circular design, recycling and re-use opportunities at the design stage — which is what the Ecodesign for Sustainable Products legislation is all about achieving in the first place. 

Meanwhile, a Digital Product Passport must reflect the reality of what was actually purchased and used, and by which suppliers in each product line. 

Therefore, you might want to combine information from both your PLM (around care and circular design) and from a Supply Chain Traceability tool, like Segura, to create a comprehensive DPP.  

The good news is that data from PLMs and Segura can be shared via Application Programming Interface (API) or Electronic Data Interchange (EDI), which allows real-time integration, as required, with existing systems at all tiers of the supply chain. 

However, on its own a PLM is not going to carry the data required for legislative compliance around DPPs."
    }
  }]
}
```