Digital Product Passports for SMEs

The most common question from a company under two hundred people is whether any of this applies to them. The hopeful reading is that product regulation targets large manufacturers and leaves smaller ones alone. That reading is wrong, and acting on it is expensive.

Regulation (EU) 2024/1781 contains no general exemption by company size. What it contains is a requirement that the Commission take proportionality into account when preparing delegated acts, and scope to treat micro-enterprises differently within a specific product group. That is a much narrower thing than an exemption, and it is decided group by group rather than in advance.

Why the real deadline is commercial

For a small manufacturer the regulator is rarely the first party to ask. Large buyers inherit obligations and pass them up the supply chain contractually, typically well before enforcement begins, because they need the data in place before their own deadline.

That changes the risk profile entirely. Missing a regulatory date produces enforcement risk in a market. Missing a customer’s data request produces a lost account, immediately, with no transition period and no appeal.

Where the cost actually sits

SMEs consistently over-estimate the software cost and under-estimate the data cost. The distribution is not close.

The practical consequence is that selecting a platform before completing a gap analysis inverts the work. You end up paying for capability against data you do not yet hold, and discovering the gap only when you try to publish.

What being small makes easier

The framing that helps is that scale is a disadvantage here, not an advantage. A group with forty product groups across nine markets is managing a portfolio of obligations. A company with one product group and thirty suppliers is managing a task.

• Fewer product groups means fewer delegated acts to track, and usually one data set rather than several conflicting ones.
• Shorter supply chains mean the person holding the missing attribute is often one call away rather than three tiers down.
• Direct supplier relationships mean a data request goes to someone who knows your name, which materially improves response rates.
• No legacy systems means passport data can be assembled from the spreadsheets you already maintain rather than extracted from an ERP nobody fully understands.

A proportionate sequence

The following order keeps cost down by refusing to buy anything until the shape of the problem is known.

Steps one to three can be done by one person in a week with a spreadsheet. Step four is the long pole and should start immediately, because supplier response time is the only part of this you do not control.

What to say to a customer asking early

A large customer asking for attributes you do not yet hold is not a crisis, and the worst response is an invented figure. Suppliers who estimate under pressure create the data quality problem that surfaces two years later during an audit.

The response that preserves the relationship is a partial return with an explicit gap list and a date: here is what we hold and where it came from, here is what we do not measure, here is when we expect to. Buyers with a functioning compliance team recognise that as a supplier in control of their data, which is a better signal than a complete-looking submission that falls apart on inspection.

Shared and pooled approaches

Smaller manufacturers in the same sector frequently need identical attributes from identical suppliers, and there is no reason to ask separately. Trade associations in textiles and furniture have begun coordinating attribute requests, which raises response rates because the supplier receives one recognisable format rather than nine variations.

The same logic applies to testing. Microfibre release, abrasion and durability tests are priced per test rather than per company, so a shared test on a common fabric or component produces a figure several members can legitimately cite, provided each records that the result came from a shared sample rather than their own production.

The thing worth spending on

If the budget only stretches to one thing, spend it on recording where each figure came from. Provenance is what converts a number into evidence, and it is almost free to capture at the moment the data arrives and almost impossible to reconstruct later.

A small manufacturer with thirty attributes, each carrying the name of the person who asserted it and the date they did, is in a stronger position than a large one with three hundred attributes and no idea which are measured and which were assumed.