Compliance does not need a six-figure IT budget, and the law says so

A widespread assumption about the digital product passport (DPP) is that it is a large-company problem requiring a large-company budget: a data platform, an integration programme, consultants.

The regulation was written with the opposite intent, and the support provisions are worth knowing before anyone signs off a six-figure project.

What Article 22 promises SMEs

The Ecodesign Regulation recognises the role of small and medium-sized enterprises and contains specific provisions to support them, at both European and national level.

From the Commission. When new passport rules are adopted for a product group, they will be accompanied, where appropriate, by targeted guidelines covering the specific needs of SMEs, and by freely accessible digital tools to assist with implementation.

From member states. Each member state is required to consult SME organisations and take appropriate measures, including mandatory one-stop shops or similar mechanisms to raise awareness and create networking opportunities. Additional support is possible in line with state aid rules: financial assistance such as fiscal advantages, specialised training, and organisational or technical assistance.

Before the rules apply. Before a passport becomes mandatory for any product, the Commission must conduct public consultations and an impact assessment that specifically considers effects on SMEs. That is also a route to contribute, directly or through a trade association.

What this changes about the build decision

Free tools will exist for the basics. Where the Commission provides digital tools for a product group, a small company may be able to meet the minimum requirement without buying anything. Budget should be checked against what will be available rather than assumed.

The support is per product group. It arrives alongside the delegated act for your category, not in advance of it. So the question to ask your national authority is what is planned for your category, and the answer may change your timing.

Where budget is genuinely needed

Being honest about where the support does not help.

The Commission's tools will address the technical burden of creating and serving a passport. They do not collect your supplier data, which is the expensive part for a company of any size. In the KPMG survey of more than 70 European organisations, collecting data from suppliers was the most cited challenge at 31 percent, while budget constraints were cited by 11 percent and senior-level support by 3 percent.

That ordering is the useful finding. The scarce resource in passport readiness is not money. It is supplier responsiveness and internal attention, neither of which a tool provides. As with all figures from that survey, the sample is small and self-selected, so treat it as directional.

The DPP service provider route

The regulation also anticipates that many businesses will not build anything at all. It provides for specialist DPP service providers: independent companies offering the data hosting and management needed to host a passport, including the legally mandated back-ups.

For many businesses, the Commission notes, this will be a straightforward way to ensure compliance, because the provider handles the technical requirements. That is a route the regulation explicitly contemplates rather than a workaround.

Where to point the budget

Check what SME support applies to your product category with your national authority. Find out whether your category has an adopted act, since the support arrives with it. Then size the budget against the supplier data work rather than the software, because that is where the effort actually lands.

Sources

• European Commission, *Digital Product Passport: FAQ*, January 2026 update, questions 8 and 10.
• Regulation (EU) 2024/1781 (ESPR), Article 22 on SME support.
• KPMG, *European Digital Product Passport Readiness Survey*, February 2026. Small self-selected
• sample, weighted toward textiles and footwear.