There is a word increasingly muttered across retail boardrooms: confusion.
Digital Product Passports (DPPs) – the EU-backed system designed to embed detailed product data into everything from clothing to electronics – have been billed as the next era of supply chain transparency.
Yet, for many brands, the reality today is that clarity around the scheme has been slow to emerge. A recent study from GS1 found that only 16 per cent of UK businesses feel fully prepared, while a further 79 per cent fear they could lose the ability to trade with the EU altogether.
And industry confusion can be justified. The actual launch date is a “bit of a moving piece”, says GS1 engagement manager Laura Milillo. While some sector-specific rules are expected in 2027, the wider rollout has yet to be finalised.
“It’s a really ambitious project… a fundamental transformation of how products are [managed],” says Milillo. “Any big transformation… has what we call transition risk.”
However, the cost of getting it wrong could be significant; the same GS1 report suggests failure to prepare could cost the average UK business £1.5m a year in lost EU trade.
Retail Gazette sat down with Laura to learn about DPP scheme, to debunk any misconceptions and just what opportunities, or pitfalls, lie for brands as it implementation date draws closer.
What is DPP?
At its core, Milillo says, DPP is often misunderstood.
“Often when people look at the digital product passport, they think of it as a finite kind of objective unto itself… everything now needs to have a DPP, not quite why,” Milillo explains.
Instead, she frames it as infrastructure – a system designed to support a broader economic shift in how products are made, tracked and sold, through the digitisation of its supply chain. It is a system-level economic reform, not just sustainability policy.
“The objective really [is] to decouple economic growth from resource use… digital product passport is the tool to help deliver that when it comes to product,” Milillo says.
In practice, this means embedding detailed data into products, from material composition to repairability, accessible via a digital link, most likely a QR code. This information can then be used across the product’s lifecycle, from resale to recycling.
The scope is vast. DPP is expected to affect almost all retail and FMCG products, excluding food and medicine. While final requirements are still being defined, likely data points include country and factory of origin, environmental metrics such as carbon and water usage, durability, safety, organic and fairtrade certifications, and end-of-life instructions.
And while the EU is leading the charge, it is not acting alone. “China is also doing a DPP scheme, moving at the same pace or even faster,” Milillo notes.
For retailers, once implemented the immediate implication is stark: full visibility. DPP will require companies to trace products across increasingly complex, global supply chains – often exposing gaps in data that many businesses do not yet have.
“Do you have the data? Can you share it? How well and how seamlessly can you share it?” Milillo asks.
For some, this will be manageable, or even a chance to showcase their sustainability credentials, but others may face a more abrupt reckoning.
“Some brands have invested very proactively in that traceability. For them, it is likely that something like digital product passports will not be as much of a rush to the finish line.” But for those that have not, the implications could go beyond compliance.
Scenario one – the ESG reset
One of the most significant outcomes may not be operational, but reputational. As DPP embeds transparency into the system, a potential consequence is that brands’ sustainability claims will be harder to separate from reality.
“ESG might move from something that is almost separate from the business… to something that becomes a given,” Milillo says. “We’re raising the floor for what that means for businesses.”
DPP will require f comprehensive information about each product’s origin, materials, environmental impact, at a time when many brands are already under scrutiny for greenwashing.
A recent European Commission study found that 53 per cent of examined environmental claims made by companies were vague, misleading, or unfounded, while 40 per cent lacked any supporting evidence.
For an industry where sustainability has often been led by marketing, this shift could force it into core operations, aligning what brands say with what their supply chains actually show. It is not difficult to imagine a wave of brands reassessing, or toning down, previously bold environmental claims.
Scenario two – will supply chains shrink?
Another potential consequence frequently raised is localisation. If tracking global supply chains proves too complex or costly, could brands simply shorten them?
Milillo stops short of predicting that outcome.
“Whether localisation is better or global supply chains, that’s very much for businesses to make,” she says.
What DPP does offer, however, is the data to make that decision. “Businesses that are able to understand the supply chain can make those decisions with a better… more data-driven point of view.”
In that sense, localisation may not be mandated, but it may become, in some cases, the simplest option.
And, in a supply chain sector where geopolitical shocks have caused global shipping to ground to a halt through both physical blockades in key waterways, and a surge in price for fuel, this might naturally be the future many brands are already heading towards.
Scenario three – the upside: a second-hand revolution
If there is an optimistic scenario, it lies here. Milillo says the desired outcome could be that DPP could give a boost to a sector, such as a transformation the second-hand market, turning it from a fragmented ecosystem into something closer to mainstream retail.
“DPP is not sustainability for the sake o it, its about economic growth,” she says. “Lets not forget that. Economic growth could come from a different type of consumption, for example, with a very well enabled resale market.”
“Imagine… every garment has a digital passport. You could scan that DPP and upload that information into a resale platform,” Milillo explains.
“You’ll be able to see where it came from, when it was bought, or if it’s been altered.”
The result? A resale experience that mirrors buying new. “That resale experience [could become] very similar to a first purchase experience.”
Resale platforms like Depop, Vinted and eBay stand to benefit, but so too do brands with willing to engage through ‘second life’ or circular recycling systems.
Many retailers have already hopped on the trend, such a M&S, Nobody’s Child and Decathlon, with the DPP potentially creating the opportunity for other brands to start having those conversational internally, or with other resale platforms, or logistics and recycling partners.
“Is it a threat, or is it something to embrace and recapture some of that value and also be sustainable at the same time?” Milillo asks.
For fashion, in particular, this could open entirely new revenue streams, and extend product lifecycles far beyond the first sale, through AI-driven shopping or data-led recycling systems.
“If you have full visibility, you can probably make decisions much faster [and] pinpoint where things are going wrong. Consumers now can make very informed choices, whether it is around sustainability, safety or human rights.”
A reckoning, or a reset?
What type of reinforcements will be there for retailers who do not comply, we do not yet know says Milillo,
She muses that brands might face fines or other penalties, such as goods being stopped at the borders, measures that could vary depending on the product category.
However an industry built on globalisation and opacity, Digital Product Passports represent something more than regulation.
For any worried brands, Milillo stresses that they are “not just const centres” but instead “opportunities”.
“These are things that business can do to make their supply chains more effient, rom a consumer connection point of view. And as the final details [of the DPP scheme] are being worked out, it could be an interesting exercise for businesses to get ready in some of these areas”.
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