DPP Uncertainties: A Survival Guide for MENA Fashion SMEs. Digital Product Passport PART 2
Disclaimer: This article is for information only and is not legal advice. Consult qualified advisers for guidance specific to your business.
Picking up where we left off
In Part 1 we explained what the EU’s Digital Product Passport (DPP) is, why Middle-Eastern exporters must care, and when the first textile deadlines fall, laying the groundwork for strategic readiness. In this second instalment, we go deeper, exploring five key unknowns and outlining practical, cost-effective steps to help your brand prepare.
Europe’s Ecodesign for Sustainable Products Regulation (ESPR) makes the DPP the passport every garment will need to cross EU borders from 2027 onward. Yet many of the nuts-and-bolts requirements will not be finalised until 2026, leaving a two-year window in which well-prepared brands can gain a competitive edge over slower rivals.
Retailers, not customs officers, are likely to be the first line of enforcement, with large platforms already asking suppliers for DPP-style data in onboarding forms.
Five unanswered questions and what to do now
We have collated five themes around which there are still significant uncertainties when it comes to DPP regulations. They are summarised in the table below, with a more detailed analysis in the sections that follow:
1. Which data fields will finally be mandatory?
Today, the ESPR only lists broad categories (composition, environmental performance, circularity), leaving brands guessing whether full cradle-to-grave Life-Cycle Assessments (LCAs) or just fibre percentages will be required. A full LCA on a 20-SKU collection can cost €8,000-15,000; guessing wrong could put a dent in an SME's budget.
Do now
Capture what you already have: SKU codes, fibre mix, country of origin, certifications (GOTS, OEKO-TEX).
Store it in a shared spreadsheet or low-cost traceability app that exports CSV or via API.
Ask tier-1 suppliers for any process data they can provide; layer deeper data in gradually through 2025-26.
2. Who will be liable when something goes wrong?
If a product with a faulty or missing DPP enters the EU, who gets penalised? The ESPR lets member states fine up to €20 million or 4 % of global turnover. It does not yet spell-out whether the brand, importer or the retailer gets penalised. EU-based importers will likely hold the formal responsibility, meaning they will push compliance demands down the chain.
SMEs that sell through multiple distributors or marketplaces need clarity on who owns the DPP submission. Without contracts in place, they risk losing deals or worse, being blamed for non-compliance.
Do now
Ask every EU buyer how they intend to lodge DPPs and what evidence they want from you.
Update contracts to define data duties and dispute resolution paths.
Nominate one “DPP owner” internally so requests do not fall through the cracks.
3. How will “circularity” be scored?
The DPP is designed to support the circular economy. The regulation talks about recyclability, repairability and longevity, but there is no standard metric for garments.
Can you label a cotton-poly blend as “recyclable” if infrastructure doesn’t exist in every country? Can brands self-score repairability? There are a lot of open questions around the circularity point.
Poorly supported claims could expose your brand to legal and reputational risk. Over-claiming could breach the forthcoming Green Claims Directive, while under-claiming could make genuinely circular items invisible.
Do now
Design with mono-materials or detachable trims to make recycling simpler.
Run indicative LCAs or recyclability checks with cloud tools such as Carbonfact or TrusTrace; even a €500 desktop study beats guesswork.
Phrase benefits conservatively - e.g. “designed for 90 % fibre-to-fibre recycling where facilities exist.”
4. What will enforcement look like in practice?
Border agents cannot scan every carton, but e-commerce giants can refuse a listing instantly. The most immediate enforcement may not come from regulators, but from retailers. Companies like Zalando are already asking for DPP-style data. That trend will only intensify, especially in luxury and multi-brand retail.
Some other open questions also remain:
Will customs agents scan every DPP? The volume of small parcels entering the EU makes 100 % inspection impossible. Risk-based sampling at the border will be a more likely scenario. A central EU registry of DPP identifiers, due by July 2026, will let customs officers ping a product ID against the database before deciding whether to open a box. High-risk profiles (unknown importer, missing data fields, prior non-compliance) will receive more scrutiny, while low-risk shipments may sail through.
Will retailers be audited? Yes, most likely. Under the Market Surveillance Regulation (EU) 2019/1020 and a July 2025 Parliament resolution, platforms and large retailers are now squarely in the cross-hairs. Retailers, therefore, have two incentives to audit suppliers:
Legal liability - If they place a non-compliant product on the EU market, they (and not the overseas brand) pay the initial fine.
Operational risk - A failed audit can trigger recalls, product delisting and negative PR.
Do now
Treat DPP readiness as a sales pitch: offer a retailer a two-SKU pilot with QR-linked passports and gather feedback early.
Keep a one-page “DPP tracker” in Google Sheets (SKU, status, next actions) updated weekly.
5. Which tech platforms are future-proof?
There is currently no official EU list of approved platforms, and there may never be one. Vendors range from blockchain-heavy Circularise to PLM-adjacent incumbents. Choosing the wrong tool could mean costly rework, data incompatibility, or vendor lock-in. SMEs especially need systems that are affordable, modular, and future-proof. Should data be hosted in the EU? Will QR links need to remain accessible forever? These questions are still open.
Do now
Shortlist tools that export data freely (open APIs), publish roadmaps, and sit in EU pilot programmes.
Sign only short contracts until 2026 delegated acts are final.
Start small, and avoid building anything custom just yet
In Part 3 of this series, we’ll do a deep dive on the top tech partners and tools available, how to choose the right one for your business, and what to look for in a compliance-ready solution.
Building the data staircase
The diagram below shows the “data funnel”: at the base sits information every brand records already; the middle layer holds deeper supplier metrics; the top layer is the full DPP field set.
Use the base layer first, add one or two middle-layer metrics each season, and reserve the top-layer roll-out for the year before DPP enforcement. That staged climb keeps budgets predictable and avoids the last-minute data scramble.
A quick win: add a small QR code to every care label, linking to a landing page with fibre composition and care tips. Updating that page later with recyclability scores or repair videos costs pennies yet tells buyers you are future-fit.
Regional Call to Action
Governments and trade associations in the region must act now to help SMEs stay competitive. Here is what we would love to see:
Offer free workshops on traceability and DPP prep through chambers of commerce.
Build a shared knowledge hub with vetted tech tools and resources.
Collaborate with the EU-GCC Dialogue on Economic Diversification to align timelines and expectations.
Lean in early, iterate often
Waiting for perfect clarity feels safe, yet history rewards the brand that prototypes first and tweaks later. Start gathering core data, nurture supplier transparency, and trial a micro-passport on one hero SKU. When 2027 arrives, you will not merely comply, you will use the DPP as proof of quality, traceability and integrity, three attributes European buyers now rank as highly as design.
👉 Want help navigating DPP readiness? Contact us at to explore workshops, resources, and regional partnerships.
