DPP for Small & Medium Enterprises
ESPR's Digital Product Passport obligations apply to SMEs — but with important differences in timing and scope. Here is what smaller companies actually need to do, and when.
Does ESPR apply to my SME?
If your small or medium-sized business places physical products on the EU market — as a manufacturer, importer, or distributor — ESPR applies to you. Regulation (EU) 2024/1781 does not exempt SMEs from the core obligation to comply with ecodesign and Digital Product Passport requirements once they apply to your product category.
What ESPR does include is a proportionality principle and a transitional framework specifically designed to reduce the burden on smaller companies. Understanding the difference between what is required and what is different for SMEs is the most important thing you can do right now.
What is the proportionality principle?
ESPR's proportionality principle means that the specific requirements set by product delegated acts may be adjusted to reflect the size and capacity of the companies involved. This happens at the delegated act level — when the Commission adopts rules for a specific product category (like textiles, steel, or electronics), those rules can include:
- Phased timelines that give SMEs more time to comply than large companies in the same category
- Simplified DPP formats with reduced data fields for smaller operators
- Lighter administrative requirements where full compliance would be disproportionately costly
The proportionality principle is stated in ESPR's recitals and reflects a deliberate policy choice: the regulation should not drive small manufacturers out of the EU market.
What SMEs actually need to do vs enterprises
What is the same for everyone:
Once a delegated act enters into force for your product category, your product must comply with the ecodesign performance requirements — durability, repairability, recycled content, substance limits. There is no size exemption from the performance requirements themselves.
You must also register a DPP in the EU registry and attach a data carrier (QR code or similar) to each product before placing it on the EU market.
What is different for SMEs:
The timeline may be longer. Delegated acts routinely include transition periods before compliance is mandatory — and those periods may be longer for smaller companies. After a delegated act is adopted, companies typically have at least 18 months to comply; SME-specific provisions within a delegated act may extend this further.
The data requirements within the DPP may be simplified. The Commission has indicated that smaller companies should not face the same granular data collection burden as large multinationals.
You are also exempt from the heavier obligations under related regulations. For example, CSRD's mandatory reporting scope — after the Omnibus package — now starts at companies with more than 1,000 employees and more than €450 million turnover. Most SMEs are entirely outside CSRD scope.
When do SME obligations begin?
There is no single date. ESPR DPP requirements apply product category by product category, set by delegated acts. The DPP registry goes live in July 2026, but the obligation to use it depends on when your product category's delegated act enters into force.
The current ESPR working plan (COM(2025) 187 final, adopted 16 April 2025) targets delegated acts for:
- Iron and steel: 2026
- Textiles and apparel: 2027
- Aluminium: 2027–2028
- Furniture: 2028
After a delegated act is adopted, there is typically an 18-month implementation window before enforcement. For SMEs, this window may be extended further within the delegated act.
If you are unsure whether your product category is covered yet, check the ESPR working plan or the Commission's Green Forum implementation page.
Practical first steps for SMEs
Step 1: Identify your product category
Is your product included in the current ESPR working plan? If yes, find out the target date for the delegated act. If your category is not yet listed, you have more time — but the framework still applies eventually.
Step 2: Understand your role
Are you a manufacturer, importer, or distributor? If you manufacture the product yourself, you carry the DPP creation obligation. If you import from outside the EU, you may inherit manufacturer obligations if your supplier has not appointed an EU Authorised Representative.
Step 3: Start collecting basic product data
Even if your delegated act is years away, the data collection process is the hard part. Start mapping your material inputs, your key suppliers, and your product specifications. This work does not need to be DPP-ready immediately — it just needs to begin.
Step 4: Review your supplier contracts
If you rely on suppliers for material composition data, your contracts should require them to provide it. This is easier to negotiate on a new contract than to retrofit later.
Step 5: Watch for your delegated act
When the delegated act for your product category is published, the compliance clock starts. Subscribe to updates from the Commission's Green Forum or use Norruva to track when your category comes into scope.
The SME advantage
Large enterprises must implement DPP infrastructure across thousands of product SKUs simultaneously. SMEs with focused product ranges can often implement a DPP solution faster and at lower cost per product than enterprises — if they start before the deadline creates urgency.
Sources
- Regulation (EU) 2024/1781 (ESPR), recitals and Articles 4, 9–13 — proportionality principle and DPP obligations — EUR-Lex
- ESPR Working Plan 2025–2030 (COM(2025) 187 final, 16 April 2025) — EUR-Lex
- EU Commission Green Forum — ESPR implementation: green-forum.ec.europa.eu
- Omnibus Directive (EU) 2026/470 — CSRD scope changes, published OJ 26 February 2026