Readiness is a deadline problem, not an awareness problem

There is a comfortable assumption inside a lot of companies that the digital product passport (DPP) problem is one of information: once people understand it, they will act.

The survey data says awareness was solved a while ago, and nothing followed.

The numbers

In a KPMG survey of more than 70 organisations across 13 European countries, with fieldwork between September and December 2025:

97 percent had heard of the DPP, and 64 percent self-identified as very knowledgeable.

33 percent reported a high understanding of the requirements and implications for their company. 58 percent reported moderate understanding, 9 percent low.

23 percent had not started any preparation work.

23 percent had not assigned internal ownership.

An earlier Impinj survey of supply chain professionals found that more than a third, 37 percent, did not expect to meet the DPP compliance deadline.

Both samples come with caveats worth stating. The KPMG sample is small, self-selected and weighted toward textiles and footwear at 44 percent, and KPMG sells DPP advisory services. The Impinj survey does not disclose its sample or fieldwork date, and Impinj sells RAIN RFID technology. Neither is a neutral market measurement. The gap between 97 percent aware and 33 percent understanding is large enough that the direction survives the caveats.

Why awareness does not convert

Three structural reasons, and none of them are solved by more explanation.

The obligation is category-specific and mostly indicative. A company that reads about the DPP learns it is coming, then finds no settled date for its own products, because most delegated acts are not adopted. "Coming eventually" does not compete for resources against this quarter's targets.

The work does not look like the deadline. The deadline is a filing. The work is supplier data collection, which takes twelve to eighteen months and starts long before anyone can tell you the exact field list. The connection between the two is not obvious from the outside, which is what the transition period explains.

Nobody owns it. With 23 percent reporting ownership unassigned, a large minority of companies have no one whose job it is to convert awareness into a plan. This is the single cheapest thing to fix and it is covered in who owns the DPP.

What separates the companies that will be ready

Not better information. Earlier starts on the part that does not depend on information.

Supplier mapping, evidence collection and internal ownership are all things a company can do before its delegated act exists, and none of that work is wasted whatever the final field list says. Composition, origin, facility identification and substances of concern appear in every draft so far.

The teams that make the deadline started on the data. The ones that will miss it are still waiting for certainty that arrives 18 to 36 months before the obligation, at which point the supplier conversation is on somebody else's schedule.

The uncomfortable version

If awareness is at 97 percent and a quarter of companies have not started, then the deadline will not be missed by companies that did not know. It will be missed by companies that knew and waited.

Sources

• KPMG, *European Digital Product Passport Readiness Survey*, February 2026. Fieldwork September to
• December 2025, more than 70 organisations across 13 countries; sample weighted toward textiles and
• footwear (44 percent).
• https://kpmg.com/xx/en/our-insights/esg/european-digital-product-passport-readiness-survey.html
• Impinj survey of supply chain professionals, reported in Textile World, June 2025: 37 percent do
• not anticipate being able to meet the DPP compliance deadline; 49 percent cited concerns about
• their organisation's ability to meet requirements.