No data, no sale: the passport arrives through procurement first

Most digital product passport (DPP) planning is organised around a compliance date. Find your category, find the deadline, work backward.

That plan misses how the requirement actually reaches most companies, which is not through a regulator at all. It reaches them through a customer's purchasing questionnaire, and it arrives years earlier.

Why buyers ask before the law does

Put yourself on the other side of the table. You are a large manufacturer whose product category has a passport obligation coming. Your passport will have to describe materials, origin and substances of concern, and much of that data has to come from your suppliers.

You cannot wait until the obligation binds to find out which suppliers can provide it. You have to know now, because replacing a supplier who cannot is a project measured in quarters.

So you add the questions to your supplier qualification process immediately. Not because you are required to, but because your own deadline depends on the answers.

This is why the passport propagates upstream ahead of the legal timeline. Every company in scope turns into a data collector for its suppliers, and the deadline that matters to a supplier is its customer's, not its own.

The asymmetry that decides tenders

Here is what makes this a revenue question rather than a compliance one.

When a buyer asks two suppliers for product data and one answers with evidence in a week while the other says it will need to check with its own suppliers, the buyer has learned something that has nothing to do with regulation. They have learned which supplier has control over its supply chain.

That signal reads as operational maturity, and it influences decisions well beyond the specific data requested. The supplier who cannot answer does not usually get told they lost on data. They just lose.

The evidence that this is already happening

The most cited challenge in European DPP preparation is collecting data from suppliers and the wider value chain, named by 31 percent of respondents in a KPMG survey of more than 70 organisations across 13 countries, conducted between September and December 2025. It is ahead of understanding technical requirements at 25 percent, technology constraints at 14 percent, and budget at 11 percent.

Read that as a market signal rather than a statistic about difficulty. The largest problem companies report is getting data out of their suppliers, which means their suppliers are being asked, in volume, right now. Worth noting the sample is small and self-selected, skewed toward textiles and footwear, and KPMG sells DPP consulting, so treat it as a directional indicator rather than a market measurement.

What to do if you are a supplier

Assume the question arrives before the deadline. Prepare to answer it in a week rather than a quarter.

Prepare a standard answer. The same questions recur across customers. A maintained set of evidenced answers turns a recurring scramble into a lookup, which is the practical argument for keeping the record current described in process, not a file.

Find out which of your own suppliers would block you. Your ability to answer is capped by theirs. That mapping is step 4 of the readiness checklist and it is the longest part of any passport project.

The compliance date is when it becomes illegal. Procurement is when it starts costing money.

Sources

• KPMG, *European Digital Product Passport Readiness Survey*, published February 2026. Fieldwork
• September to December 2025, more than 70 organisations across 13 countries. Sample is small and
• self-selected, weighted toward textiles and footwear.
• https://kpmg.com/xx/en/our-insights/esg/european-digital-product-passport-readiness-survey.html