Executive Summary
On 22 October, Net Solutions hosted more than 25 retail leaders at The Dixon, Tower Bridge, for a morning on the Digital Product Passport (DPP), with our partner Fabacus. Julian Burnett, CEO and Founder of Quercus, chaired a panel of Andrew Xeni (Founder and Chairman, Nobody’s Child), Jamie Beck (SVP Sustainability, Fabacus), Charlotte Harris (Engagement Manager, GS1 UK) and our own Andrew Jackson-Proes, Chief Revenue Officer. One question framed the session: is the DPP a compliance burden or a growth opportunity?
The chair asked for a show of hands. Two or three people out of more than 25 said compliance. Everyone else said opportunity.
That result is the story. The DPP is usually discussed as incoming EU regulation, something to be endured. The people in the room, who will have to pay for it, don’t see it that way. This report covers why, what they said is hard about it, and the practical advice the panel gave on where to begin.
The short version
- The room has moved on from compliance. Asked whether the DPP is mainly a compliance requirement, two or three hands went up out of more than 25. The rest see revenue and strategic value.
- The regulation will arrive lighter than the scaremongers say. Fabacus’ read of EU priorities is that requirements start light and strengthen over time. Plan for the direction, not the worst case.
- Data accuracy, not technology, is the hurdle. A DPP surfaces data that has never left the business. In some retailers, only about 20% is fully accurate. The passport makes the gaps visible.
- Smaller suppliers can do it with focus. Nobody’s Child supports its supplier conversations with 1.5 FTEs.
- AI engines are hunting for trusted product data, and a DPP is exactly that. Net Solutions’ AI visibility work for Nobody’s Child shows the passport-building authority with the brand’s target buyers.
- Work front to back. Start with what shoppers and AI can see, then map back to the data. Fix what the revenue depends on first.
More than a compliance exercise
A DPP is a structured, machine-readable record of a product: what it’s made of, where it came from, how it was made, how to repair or recycle it, and what sustainability claims can be substantiated. It’s reached through a data carrier on the product, usually a QR code. The EU is making it mandatory under the Ecodesign for Sustainable Products Regulation (ESPR), product group by product group. Textiles and apparel are in the first wave, with the apparel delegated act targeted for 2027 and compliance expected to follow in 2028 or 2029. The EU’s central DPP registry went live in July 2026.
That is the regulatory frame, and it’s the one most retailers have heard. Julian Burnett opened by arguing it’s the wrong frame. The DPP sits at the meeting point of two bigger shifts in retail.
The first is AI search. Capgemini’s consumer research found 58% of shoppers have replaced search engines with generative AI tools for product and service recommendations, up from 25% in 2023. Adoption keeps climbing: the St. Louis Fed’s tracker had 54.6% of US working-age adults using generative AI by August 2025 and 57.9% by January 2026. Large language models run on structured data, which is exactly what a DPP provides. A brand with a well-built passport has handed AI engines a trusted description of every product it sells.
The second is supply chain transparency. GS1 has set a global ambition, Sunrise 2027, for retail point-of-sale systems to read next-generation 2D barcodes by the end of 2027. Consumers, regulators and trading partners all want visibility of provenance, sustainability and stock accuracy, and the 2D code is the carrier that links a physical product to that data.
The data a DPP requires also rewires operations. Real-time stock visibility, less supply chain waste, smoother product recalls, and sustainability claims you can prove, which cuts greenwashing risk. Treat it as a compliance checkbox, and you leave market share, margin, and savings on the table.
What we heard in the room
The regulatory picture is pragmatic. Jamie Beck, SVP Sustainability at Fabacus, opened with a DPP primer and his view of where EU priorities and timelines will land. He has contributed to panels at the heart of the DPP process, and he believes requirements will be lighter at the start and strengthen over time. His warning: be wary of vendors scaremongering about how fast and how much will be required.
The room isn’t treating this as compliance. Julian Burnett asked who sees the DPP mainly as a compliance requirement rather than a source of revenue and strategic value. Two or three hands out of more than 25. The leaders in the room have already made the mental shift that most of the market hasn’t.
Data accuracy is the real hurdle. Jamie’s experience of retailers is that data accuracy is often low. In some organizations, he said, only around 20% of data is fully accurate. A DPP needs data buried deep in the business that rarely sees the light of day outside it. Surfacing it exposes the gaps: spelling mistakes, inconsistencies between systems, and records that should be complete but aren’t. The technology is the easier half. The data is the work.
Making it work in practice
Smaller suppliers can do this. Labeling and QR codes are hard for smaller retailers and suppliers, some of whom lack the knowledge or processes, even when their retail customers ask for them. Andrew Xeni, Founder and Chairman of Nobody’s Child, spoke from experience. The brand has carried DPPs on its care labels since 2023, with more than 100 data points per garment. Education and focus got it there, and only 1.5 FTEs support those supplier conversations today. It’s achievable. It needs focus, not headcount.
Buy-in means speaking to each stakeholder in their own terms. In a large enterprise, the DPP touches commercial, sustainability, supply chain, digital and legal, and winning all of them is hard. Andrew Xeni pointed to the materials Fabacus has developed that frame the benefits for each function separately, which he saw as essential. The finance director and the sustainability lead are not persuaded by the same slide.
Trust powers commerce, and AI is hunting for it. Andrew Jackson-Proes, Chief Revenue Officer at Net Solutions, explained that AI engines constantly search for authoritative content to ground their answers, and DPP data is a strong source of trusted, structured product data. Net Solutions’ AI visibility work for Nobody’s Child showed the DPP helping build the brand’s authority with its target buyers in responsible and ethical apparel. The effect shows up in the data.
Work front to back. Andrew Jackson-Proes’ practical advice was to start with what shoppers and AI engines can see, then map back through the eCommerce platform to the back-end systems and data. That way the data readiness work is prioritized against real revenue opportunities and visibility gains, rather than trying to clean everything at once. Start at the back, with a full data cleanup, and the work has no natural end. Start at the front and you know which data to fix first.
Standards, global momentum and lessons from other sectors
Standards underpin all of it. Charlotte Harris of GS1 UK noted that GS1’s work is rarely front and center, despite the organization having more than 60,000 UK members. Yet it’s central to the identifiers, data carriers and interoperability the DPP depends on. A QR code that resolves to a passport is a GS1 Digital Link; a product the passport describes is identified by a GTIN. She outlined the ways GS1 UK is helping organizations prepare.
The EU leads, others follow. The EU is ahead on the DPP. The UK government has been consulting on “digital product records”, its term for the same idea, through a call for evidence that closed in September 2026, and has not yet decided its approach for Great Britain. The EU passport will apply in Northern Ireland regardless, under the Windsor Framework. A UN-led global initiative is also underway. The group drew the obvious parallel with GDPR: it began in Europe, but the size of the EU consumer market meant anyone wanting to serve those shoppers had to comply, and equivalents soon appeared worldwide. Any UK retailer selling into the EU is in scope whatever Westminster decides.
Learn from other sectors. Panelists and attendees shared examples of how industries outside retail have adopted data-led initiatives, and what retail can offer in return. Both GS1 and Fabacus take part in cross-sector discussions to share what works.
Where to start
The chair’s closing question to the panel was the practical one: if a commercial or operations leader does one thing next week, what should it be? For most retailers, the honest first step is finding out where they stand, before anyone sells them a platform.
If you were in the room, or wish you had been, we are offering a complimentary diagnostic review. We look at your eCommerce front end and systems integration: whether your product data is structured so AI search and shopping agents can find, understand, and recommend it, and how passport data would flow between supplier systems, ERP, and the storefront. If the gap is in the data layer or operations, we bring in Fabacus and Quercus, who cover those areas.
What happens next
We run a small number of invitation-only sessions each year for commerce and technology leaders, in London and New York, some of them with partners. If you’d like to be considered for the next one, tell us where you sit and what you’re working on.
On attribution. Panelists are named. Audience members are not identified, and the show of hands is reported as a count only.
FAQs
A structured, machine-readable record of a product’s materials, origin, manufacturing, repair and recycling information, and substantiated sustainability claims, reached through a data carrier on the product such as a QR code. The EU is making it mandatory under the Ecodesign for Sustainable Products Regulation, one product group at a time.
The EU’s apparel delegated act is targeted for 2027, with compliance expected to follow in 2028 or 2029 after a transition period. The exact dates will be fixed in the act itself. Fabacus’ view, shared at the session, is that early requirements will be lighter than many vendors suggest and will strengthen over time.
Yes, for any product placed on the EU market, wherever the seller is based. Great Britain has no passport requirement of its own yet; the government’s call for evidence on digital product records closed in September 2026. The EU passport applies in Northern Ireland under the Windsor Framework.
Request it through our contact page. We review the eCommerce front end and systems integration. Where the gap is in data architecture or operational readiness, we bring in our partners, Fabacus and Quercus.
