Digital Product Passport: From a compliance project to a competitive advantage

December 18, 2025
Simon Manz

A paradigm shift for mid-sized businesses

By 2030, 90% of all product portfolios in the EU will require a Digital Product Passport (DPP).¹ What starts as a regulatory obligation has a good chance of becoming the biggest data unlock since the introduction of ERP systems (see: Why DPP?). The decisive question is no longer if, but how: Will the DPP become a bureaucratic cost burden, or a strategic growth lever?

For mid-sized companies, this transformation comes with distinct opportunities and risks. Those who act early can secure competitive advantages. Those who wait risk not only compliance gaps, but also the loss of market access and customer access.

TL;DR

The DPP should not be understood as a pure data project, but as a battle for customer ownership. If you only provide mandatory data, you lose customers to third-party platforms like Amazon and others. If you use it strategically, you unlock new revenue streams, but only with the right technical infrastructure. Mid-sized companies must orchestrate supplier data they do not own. With a PIM/DPP solution, this can be done successfully.

The invisible shift: When the customer is no longer your customer

The situation is paradoxical: 73% of buyers expect immediate mobile access to product information.² At the same time, 51% buy via third-party platforms like Amazon, and only 20% directly from the manufacturer.³ The DPP intensifies this dilemma: before the Point of Sale, marketplaces become the central information interface, while manufacturers remain data suppliers.

The fashion example: What happens when you sell via marketplaces

If a textile company sells outdoor jackets through Amazon and Zalando, the customer relationship ends with the sale. With the DPP, every jacket must carry a DPP with a QR code: material origin, CO₂ footprint, care instructions, repair options.

And then?

Scenario A (reactive): The manufacturer links the QR code to a product data sheet. Obligation fulfilled. Next time, the purchase happens again via Amazon or Zalando.

Scenario B (proactive): The manufacturer designs the DPP as its own channel. The customer scans and lands on a brand microsite with supply-chain storytelling, can add a backpack rain cover right away, receives a trade-in offer for the old jacket, and is invited to the community. By signing up for the newsletter, they get €10 off their next order. The possibilities are endless.

The DPP is not just a data project. It is a battle for customer ownership.

The three layers of a DPP strategy

1) Data architecture: The underestimated foundation

The DPP reveals what many mid-sized companies have ignored for years: product data is fragmented. Marketing maintains different information than procurement, production runs its own systems, sustainability data sits in Excel lists or is not collected at all. These silos are inefficient and become a compliance risk.

If you don’t have a Single Source of Truth (SSoT) for product data, you cannot implement the DPP at scale. Beyond a PIM, you also need a governance model that clarifies responsibilities, safeguards data quality, and standardizes processes. In practice, these are topics that must be defined top-down or someone must be given the mandate to define processes and standards.

2) Supply chain: The data challenge for mid-sized companies

The DPP forces you to provide data you often do not own. As a manufacturer, you are regulatorily responsible for complete product information, but the data sits with suppliers. And this is exactly where the challenges arise:

The fashion example (Part 2): The outdoor jacket consists of six components from four suppliers in three countries. For the DPP, you need:

  • CO₂ data for cotton production (supplier in country 1)
  • chemical certificates from the dye house (subcontractor in country 2)
  • transport emissions (logistics provider without digital tracking)

Challenge 1 – Dependency: Your fabric supplier has no software for CO₂ tracking. Your options:

  • You invest in their digitization (your cost, their system)
  • You switch to a “DPP-ready” supplier (risk quality loss, lose a long-standing relationship)
  • You estimate the data yourself (risk inaccuracy and compliance gaps)

Challenge 2 – Transparency as a risk: The DPP makes your supply chain public. A customer scans your jacket and sees not only your CO₂ footprint (15kg), but also that the competitor is at 12kg. Your material sources, your suppliers, your cost structure become readable. For you. And for your competition.

Challenge 3 – The infrastructure decision: Without a technical solution for data orchestration, the DPP becomes a chaos project. This is where the right platform pays off: specialized DPP solutions offer interfaces to supplier networks, automated data validation, and compliance checks. You do not need to manually consolidate every Excel sheet from your suppliers.

The strategic opportunity: Those who invest in Supplier Collaboration today (shared data standards, training, digital tools) bind suppliers strategically and build quality advantages. Modern PIM/DPP platforms offer exactly these collaboration features: the ability for suppliers to maintain their own data, plausibility checks, and workflow management.

The DPP not only makes sustainability visible, but also weak spots. Greenwashing becomes technically verifiable. A company that promises transparency must deliver—or it will lose credibility in a measurable way.

3) Business model: From product to product lifecycle

The DPP opens revenue models that used to be niche topics:

  • Repair-as-a-Service: via the DPP, customers can identify and order spare parts directly—without detours via hotlines or dealers
  • Second-life markets: trade-in programs are automated: the customer scans the product and receives a trade-in offer based on condition and usage data
  • Predictive maintenance: consumables or wear parts are offered proactively before the product fails

The fashion example (Part 3): The jacket carries a digital twin in the PIM system. After three years of use, the customer scans the DPP code and receives a €40 trade-in offer. The jacket is professionally cleaned, repaired, and resold as “Certified Pre-Owned” with a two-year warranty for €90. The manufacturer earns twice on the same product and builds a loyal community along the way.

But: these models only work with the right technical foundation. A PIM/DPP system that tracks product lifecycles, captures condition data, and provides automated workflows for trade-ins makes the difference between idea and execution.

Reality check: Not every company needs a full circular economy strategy immediately. Some first need just one thing: solid baseline data. But whoever builds the infrastructure today can experiment tomorrow without starting from scratch.

The reality in SMEs: Three critical decisions

1) The speed advantage: Partner instead of in-house development

In-house development can sound tempting, but it ties up resources most mid-sized businesses don’t have. Specialized PIM/DPP providers have already built the infrastructure including regulatory updates, API integrations, and best practices from other implementations.

Where is your competitive advantage? In data administration, or in the creative use of your product data? Mid-sized companies can focus on the latter if they leave the technical foundation to a specialized partner.

Industry consortia as a third path: In some industries, shared standards and shared infrastructures are emerging. This can work, but it can also involve long alignment processes.

2) Must-have vs. nice-to-have: The pilot approach

Not every product needs the full DPP feature scope immediately. Prioritize:

  • Which product lines face regulatory pressure?
  • Which have customer demand?
  • Which have potential for new services?

Start with a pilot, not the entire portfolio. Important willingness to experiment gets lost when the DPP project is rolled out across all products right away. A pilot enables exactly that: gradual introduction, testing, iteration.

3) Control vs. openness: The transparency strategy

The DPP forces a fundamental decision: maximum transparency for trust vs. strategic restraint to protect competitive advantages.

There is no universally correct answer. A premium manufacturer with an excellent supply chain can use full transparency as a differentiator. A volume provider with optimization needs is better off with the regulatory minimum. The key is: make this decision deliberately, not by accident or under time pressure.

Three steps for tomorrow – not the day after tomorrow

  1. Start a data inventory
    Which product data exists? Where does it live? Who is responsible? This stocktake is the indispensable first step.
  2. Define a pilot product
    Choose a product with manageable complexity, but strategic relevance. Build the DPP end-to-end: from data capture to the customer touchpoint. Test different use cases: is a basic data sheet sufficient, or is it worth building a more mature user experience?
  3. Anchor governance
    The DPP is not a pure IT project. A cross-functional taskforce spanning product, sales, IT, and sustainability has the best chance of success. Clarify decision-making authority early. Define quality standards. And give someone the mandate to enforce them, otherwise the best plans will stall out in departmental silos.

Conclusion: The mid-sized businesses at a crossroads

The Digital Product Passport is neither the salvation nor the downfall of the mid-sized businesses, but a catalyst. Companies that treat it as an annoying obligation will meet compliance in the coming years, but generate no competitive advantages. Companies that understand it as a strategic instrument can secure customer access, stabilize supply chains, and unlock new sources of earnings.

What’s interesting: mid-sized companies often have better prerequisites than large corporations. Shorter decision paths, closer supplier relationships, and more authentic sustainability stories help enormously. These strengths simply need to be leveraged.

The DPP is coming. The question is not if, but who ultimately benefits from it.

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¹ Estimated value based on expert assessments
² Gitnux 2025 | Customer Experience in the Industrial Industry Statistics | gitnux.org
³ Akeneo 2025 | New Akeneo Survey Reveals Reviews, Transparency, and Trust Outweigh Discounts in 2025 Holiday Shopping | prnewswire.com

Simon Manz

Simon is an entrepreneur and executive coach. With over five years of experience at BCG and the founding of entitys, he focuses on supporting medium-sized companies in their growth and transformation. His focus is on pragmatic solutions that enable sustainable success.

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