Why Delaying Digital Product Passport Preparation Is Becoming a Commercial Risk

As 2026 begins, Digital Product Passports are no longer a future regulatory concept. They are steadily becoming a practical requirement for placing products on the EU market.

December marked the point where Digital Product Passports moved firmly into the core of EU product compliance. January has built on that shift, not through new legislation, but by clarifying the operational and commercial consequences of delay.

So what do businesses risk losing if they postpone preparation as implementation gathers pace.

What’s New

January did not introduce new Digital Product Passport legislation, but it did deliver several important signals about how DPPs will function in practice.

Under the Ecodesign for Sustainable Products Regulation (ESPR), Digital Product Passports are increasingly framed as a condition of market access, rather than an optional transparency measure. Regulatory commentary this month reinforced that DPPs will be used by market-surveillance and customs authorities as part of existing enforcement processes overseen by the European Commission and national authorities.

At the same time, industry and policy briefings continued to point to textiles and apparel as one of the next major sectors likely to see detailed DPP requirements through delegated acts. While no new acts were published in January, the expectation that businesses should already be preparing has become increasingly explicit.

Crucially, January also saw continued confirmation that central DPP infrastructure is approaching delivery in 2026, signalling a shift from policy frameworks to system-level enforcement readiness.

The Cost of Not Preparing for Digital Product Passports

January’s developments have sharpened the cost question around Digital Product Passports.

Operational

Organisations that postpone preparation are more likely to face emergency data-collection exercises, manual supplier tracing and rushed system integration once sector-specific rules apply. These activities are resource-intensive and difficult to scale, particularly across complex product portfolios.

Commercial

As EU buyers and partners begin to treat DPP readiness as a proxy for regulatory reliability, suppliers without structured product data risk slower onboarding, loss of preferred-supplier status, or exclusion from certain value chains altogether.

Exporters who fail to meet DPP requirements could risk losing around £1.5m in annual revenue, with 79% of surveyed managers concerned that they could be prevented from trading within the EU.

Regulatory

Digital Product Passports are designed to support enforcement through digital verification. Incomplete, inaccurate or inaccessible product data can result in delayed shipments, rejected products or temporary withdrawal from the EU market until compliance issues are resolved.

January has made clear that the cost of Digital Product Passports is not the passport itself, it is the price of late, reactive remediation.

How TAZAAR Can Help

As Digital Product Passports move from policy into execution, the challenge for manufacturers and exporters is no longer understanding the regulation. It is turning fragmented product information into structured, reliable data that can support DPP requirements at scale.

TAZAAR helps organisations prepare by:

• Mapping existing product and supply-chain data to emerging DPP requirements

• Structuring and validating product-level information so it can be consistently surfaced through Digital Product Passports

• Supporting integration across ERP, PLM and compliance systems to avoid duplication and data silos

• Enabling scalable DPP readiness that can adapt as new delegated acts and sector-specific rules come into force

By focusing on product data foundations now, businesses can reduce long-term compliance cost, avoid disruption, and position themselves to operate confidently as DPP requirements expand across sectors.