"We're just a 12-person company — the product passport surely doesn't apply to us." That's the most common sentence you'll hear about the Digital Product Passport (DPP). And it's also the most common misconception. DPP obligations do not depend on company size — what they do depend on is the role you play in the supply chain and whether your product category is on the EU's priority list. The good news: these two questions can be cleared up in five minutes. Let's dive in — calmly, with no scaremongering.
The big myth: "we're small, it doesn't apply to us"
EU regulation genuinely includes SME exemptions in many places, so it's understandable that many expect the same for the DPP. But the ESPR — Regulation (EU) 2024/1781 on ecodesign for sustainable products, which entered into force on 18 July 2024 — ties the product passport obligation to the product and to your role, not to company size. Once the detailed implementing rules for a product category are adopted (a so-called delegated act), every product placed on the market in that category needs a passport — whether the manufacturer has 5 employees or 5,000.
The logic is simple: the passport travels with the product — it doesn't rate the company. A T-shirt's environmental footprint and material composition are just as important whether it was sewn by a family workshop or manufactured for a multinational chain. If you're not yet clear on what a DPP actually is, start with our beginner's guide.
It's just as important to avoid the opposite mistake: size-independence does not mean the DPP applies to everyone, to everything, and immediately. There are three filters, and you have to be caught by all three to be genuinely affected: your role, your category and the timing. Let's take them one by one.
First filter — your role: manufacturer, importer, distributor
The ESPR doesn't impose obligations on "companies" but on economic operators, and to a different depth depending on their role. The same company can wear several hats at once — a Hungarian furniture maker who imports chair legs from China and also distributes finished chairs wears all three.
| Role | Who counts as one? | Main DPP duty |
|---|---|---|
| Manufacturer | Whoever produces the product, or places it on the market under their own name or brand — even if it's actually made by someone else (private label!) | Creating the passport, ensuring the data is accurate and kept up to date, placing the QR code on the product |
| Importer | Whoever first brings a product into the EU market from a third country (e.g. China, Turkey, the UK) | Checking that the product has a valid passport — if the manufacturer failed to create one, the responsibility falls on the importer |
| Distributor / retailer | Whoever resells a product already on the EU market (wholesaler, retailer, webshop) | Making sure the product has a passport and that access (the QR code) works — a product without a passport cannot be sold |
The biggest surprise usually hits importers: many domestic retailers don't even realise that they legally qualify as importers — and therefore carry manufacturer-level responsibility. If you source from outside the Union, be sure to read our article on importer responsibility. Private-label sales are a separate trap: if your brand name is on the product, in the eyes of the law you are the manufacturer — no matter who actually sewed it.
Where size exemptions DO exist — and where they don't
So where does the "it doesn't apply to small companies" legend come from? From the fact that the ESPR really does contain a size-based exemption — just not for the DPP, but for a completely different obligation: the ban on destroying unsold consumer products (Article 25). From 19 July 2026, the regulation prohibits large companies from destroying unsold apparel, clothing accessories and footwear, while large and medium-sized companies must disclose how many unsold products they discard. Here — and only here — size matters:
| Obligation | Micro and small enterprises (under 50 employees and €10M turnover) | Medium-sized enterprises | Large enterprises |
|---|---|---|---|
| Destruction ban (unsold clothing, accessories, footwear) | Exempt (the Commission may extend the ban to them if it detects circumvention) | Transitional exemption until 19 July 2030 | Mandatory from 19 July 2026 |
| Disclosure of discarded-product data | Exempt | Mandatory (with a transition period) | Mandatory |
| Digital Product Passport (DPP) | Mandatory once the category's turn comes | Mandatory once the category's turn comes | Mandatory once the category's turn comes |
The bottom row of the table is the point: there is no size threshold for the DPP. What the EU offers smaller companies isn't an exemption but relief: the burden on SMEs must be taken into account when drafting the delegated acts, and member states must provide support measures (guidance, training, financial assistance). That's help with compliance — not release from it.
Second filter — the category: is your product on the list?
The ESPR is a framework regulation: on its own it doesn't yet require a passport for a single product. The concrete requirements will arrive category by category in separate delegated acts, and which category comes when is decided by the working plan adopted under Article 18 of the regulation. The Commission published the first working plan, covering 2025—2030, on 16 April 2025, with the following priorities:
| Product category | Delegated act (indicative) | Application at the earliest* |
|---|---|---|
| Iron and steel | 2026 | ~2027—2028 |
| Textilees and apparel | 2027 | ~2028—2029 |
| Tyres | 2027 | ~2028—2029 |
| Aluminium | 2027 | ~2028—2029 |
| Furniture | 2028 | ~2029—2030 |
| Mattresses | 2029 | ~2030—2031 |
| Horizontal: repairability score; recyclability and recycled content of electronics (EEE) | 2027—2029 | ~2029—2031 |
*The dates are indicative: as a general rule, each delegated act is followed by a transition period of at least 18 months before the requirements become mandatory (the regulation only allows a shorter period in duly justified cases) — and the detailed data requirements will only be finalised in the acts themselves. It's important to say this honestly: anyone who claims today to know exactly which fields will be mandatory in the textile passport is guessing. For the full, up-to-date timeline, see our ESPR deadlines article.
Two additions to the category check:
- Batteries run on a separate track. It's not the ESPR but the Batteries Regulation (EU) 2023/1542 that mandates it: from 18 February 2027, every EV battery, LMT battery (e-bikes, scooters) and industrial battery above 2 kWh needs a digital passport. This is the earliest DPP deadline set in stone — details in our battery passport guide.
- Some products are definitely out. The ESPR explicitly excludes food, feed, medicinal products and veterinary medicinal products, as well as living plants and animals and products of human origin. If that's your line of business, you can safely take the DPP in this form off your list.
The decision tree — four questions, five minutes
Now let's assemble the filters into a single line of reasoning. Answer in order, branch by branch:
- Do you manufacture, import or sell physical products under your own brand?
— No, I only provide services → the DPP doesn't affect you directly (at most through your clients, e.g. if they ask you for supplier data).
— Yes → on to question 2. - Does the product reach the EU market? (Even if you only sell in a single member state — say, Hungary — that's part of the internal market. And also if you ship from outside the EU to EU customers.)
— No, I sell exclusively outside the EU → the ESPR doesn't apply to you.
— Yes → on to question 3. - Is your category on the priority list above — or do you manufacture/import batteries?
— No, and it's not expected either (e.g. food, pharmaceuticals) → no DPP tasks for now; it's worth checking the working plan once a year.
— Yes → on to question 4. - Then the question is no longer whether it will be mandatory — but WHEN. The answer comes from the timetable of your category's delegated act: around 2027—2028 for steel, around 2028—2029 for textiles, around 2029—2030 for furniture — and a fixed 18 February 2027 for batteries. You can follow the exact schedule in our ESPR deadlines article.
Notice what just happened: in four steps, the question "surely it doesn't apply to us" turned into a much more useful one — "how much time do we have to prepare, and what's worth doing in the meantime?". And company size never came up once.
If this sounds like you: three calm first steps
If the decision tree left you at the "when" question, there's no reason to panic — but no reason to sit back and wait either, because the most time-consuming part of preparation isn't the software, it's the data. Three steps that pay off now:
- Assess where you stand. Which product data do you already have (material composition, origin, certificates), and what's missing? That's exactly why we built the free DPP readiness test, which walks you through question by question, tailored to your category, and shows your strengths and your gaps — five minutes, and you can start without registering.
- Start collecting supplier data. A significant share of DPP data isn't held by you but by your suppliers — and their response time is the slowest link in the chain. What to ask them for and how is covered in our article on supplier data.
- Work through a checklist. The full preparation route — from appointing an owner to the QR code — is summarised step by step in the DPP preparation checklist.
And one thought for the scales: starting early isn't just risk management — it's a competitive advantage. Large buyers and retail chains already favour suppliers who can deliver structured product data.
How does Veridyn help?
Veridyn was built precisely for the companies standing at the end of that decision tree — regardless of size — so they can comply without an IT department:
- Category-based schema editor: ready-made data fields for the priority-list categories (textiles, furniture, batteries and more), no coding required — with passports at model, batch or even individual-item level.
- QR code and GS1 Digital Link: every finished passport instantly gets a standards-compliant QR code (with GTIN + lot + serial paths), and the public view is available in all 24 EU languages.
- Supplier portal: request missing data from your suppliers via a no-login link — so you can set the slowest link in the chain in motion the earliest.
- Version history and hash chain: every change is traceable, which brings peace of mind for audits and authorities alike.
Curious what all this would look like with your own products? Check out the live demo — or start from the very beginning and take the free DPP readiness test. And once you've made up your mind, the free starter plan lets you register in a few minutes and create your first passport.