Biggest DPP Challenge Isn’t Compliance. It’s Knowing Your Own Data.
Nanna Ingemann Dalsgaard, Vice President of Sustainability, Digital ID and Marketing, SML Group
Whenever I speak with brands and retailers about Digital Product Passports (DPP), the questions are often the same.
- What data do we need to collect?
- Which regulations apply first?
- What platform should we use?
- Will DPP ultimately be implemented at SKU level or item level?
These are all important questions. But in my experience, one comes before all the others.
Do you actually know what product data you already have, where it lives, who owns it, and whether you can trust it?
At SML, we have spent decades working at the point where physical products first become digital identities. Every day we see labels, identifiers, care instructions, supplier information, serialization records, and product data flowing through factories and supply chains around the world. From that vantage point, one thing has become clear: most brands already hold a significant proportion of the information expected to be required for a Digital Product Passport.
The challenge isn’t collecting entirely new data, it’s understanding, connecting, and trusting the data that already exists, how it connects across systems, who owns it, and whether it can be relied upon.
Which brings us to the real challenge. It isn’t the passport itself. It’s the product data behind it.
Fibre composition, country of origin, care instructions, supplier details, manufacturing locations, batch records, product identifiers, and certifications – these data points already exist. They are created and used across sourcing, product development, compliance, packaging, and production.
Over time, however, that information becomes fragmented. Sustainability teams own one part, sourcing teams another, product development holds certain records, compliance maintains others, technology teams manage separate systems, while suppliers and factories hold yet another layer. This fragmented landscape is precisely what makes DPP one of the most significant transformations the apparel industry has faced, and why many brands still find the journey overwhelming.
DPP doesn’t ask whether you know your products. It asks whether you can prove what you know, whether every data point can be linked to a specific product, maintained over time, and supported with confidence. That is a much higher standard.
QR Codes Are Not the Difficult Part
Much of the discussion around DPP centres on QR codes, regulations, front-end experiences, or the evolving EU registry architecture.
Those elements matter, but they are not where most DPP programmes will succeed or fail.
A passport can be beautifully designed and still be built on unreliable data. A consumer may scan a product and see claims that cannot be substantiated or confidently explained. Meanwhile, compliance teams may discover that the underlying records are inconsistent, incomplete, or owned by no one.
As the industry moves into a new era of transparency, this is where the real risk lies. Poor data does not become trustworthy simply because it is made visible.
If a product states recycled content, where did that claim originate? If it lists a country of origin, who verified it? If it shows care instructions, have they been linked to the correct product version? If a consumer scans that same product three years from now, can the brand still demonstrate that the information was accurate when it was created?
The challenge is not displaying information. It is building a product data foundation that is accurate from the start, governed over time, and traceable back to its source.
That is also why choosing partners with deep experience in apparel manufacturing, product identity, and supply chain complexity matters. Technology alone cannot compensate for weak product data.
Transparency Starts Long Before the Consumer Scan
Many brands have invested heavily in visibility across distribution and retail. They know what is in the warehouse, what reaches the store, and what has been sold. Those investments have delivered significant value.
DPP shifts the focus further upstream to the factory floor, where product identity and product data are established for the first time.
This is where small data issues become large business problems.
If data is wrong at the source, every downstream system inherits the problem. Whether it is an incorrect label, a broken identifier, or incomplete supplier information, the passport may still function but confidence in its contents quickly disappears.
At SML, this is exactly where we operate. Every day, our solutions help establish product identities at the point where products are manufactured through labels, RFID, serialization, and data capture across thousands of factories worldwide.
Our Digital Product Passport platform builds on that foundation. Rather than introducing another disconnected system, it connects trusted product data from manufacturing through the entire product lifecycle, enabling compliance while creating value far beyond it.
For us, DPP is not simply about compliance. It is about connecting the physical and digital worlds through trusted product data, creating value for brands, consumers, and the wider ecosystem It is about transforming reliable product data into business value, from regulatory readiness to consumer engagement, authentication, and circular business models.
The Question Beneath the Regulation
Regulation is often what starts the conversation – and rightly so – but it shouldn’t define where the conversation ends.
Transparency, traceability, product information, and compliance all matter but they are not the most important part of the discussion. The deeper question is this:
Can we prove what we say about our products?
That question reaches far beyond sustainability claims. It touches traceability, authenticity, quality, circularity, consumer trust, and ultimately brand reputation.
It also changes how brands communicate with consumers.
Brand storytelling can no longer exist separately from the data that supports it. That does not make storytelling less important – it makes the evidence behind it even more valuable.
This is where DPP shifts from compliance to competitive advantage.
Transparency alone does not create trust. Trust is built when the information behind every claim is reliable.
Once reliable item-level data exists, the Digital Product Passport becomes far more than a regulatory requirement. It becomes a platform for authentication, repair, resale, recycling, richer consumer engagement, and entirely new business opportunities.
Increasingly, we’re seeing brands move forward before every detail of the Delegated Act has been finalised. They recognise that investing in reliable product data creates value regardless of where the final regulatory requirements land.
Trust Starts at the Source
The organizations that will lead in this next chapter are unlikely to be those with the most sophisticated consumer-facing experiences. They will be the ones that first establish confidence in the data behind every product they make.
Digital Product Passports may be introduced through regulation, but their long-term value will be defined by the quality of the data behind them.
Consumers don’t trust QR codes.
They trust the information those QR codes reveal.
And that trust always starts at the source.
Explore how SML helps brands transform trusted product data into Digital Product Passport readiness – and long-term business value.
LEARN MORE
