Beyond Compliance: The DPP as a Business Tool

The Compliance Trap

Preparing Digital Product Passports involves costs: collecting data, meeting regulatory requirements and delivering a system before the applicable deadline.

The same preparation can also make product information more useful to customers and business partners.

Every product that requires a DPP will need a data carrier linking to the passport data. Depending on the applicable rule, that carrier may sit on the product, label, packaging or accompanying documentation; in practice it will often be a QR code. A scan can give a consumer, retailer, customs officer or recycling partner access to relevant product information.

If the only thing behind that link is an unexplained compliance dataset (a list of materials, a recycled-content percentage, an operator name) users may struggle to understand how that information helps them.

The opportunity: A well-organised DPP can support product information, repair and other services alongside compliance. The value depends on how it is used and what the applicable rules permit.

What a DPP Data Carrier Actually Is

Before exploring business value, it helps to understand what the data carrier on your product really represents.

Under ESPR and related regulations, the data carrier on a product links to a structured digital record. The regulation is technology-neutral: it speaks of a “data carrier,” not specifically of QR codes. In practice, QR codes are the most likely implementation, but NFC tags and other technologies remain possible.

Access is governed by the applicable product rules. ESPR Article 9(2)(f) requires delegated acts to specify which actors may access which data; Article 9(2)(h) specifies the availability period. Public information and restricted business or authority data must therefore be handled separately.

For a product subject to an applicable DPP requirement, the data carrier provides access for the period required by that rule. This is a regulated product-information service, not automatic permission for marketing or tracking.

Where a DPP is required, the business question is how to make this regulated information useful while respecting the applicable rules.

Scan Signals: Operational Telemetry Without Tracking People

What you can measure responsibly

Where the applicable law permits it, the system serving DPP data can collect limited information about how the service is used. The aim should be aggregate statistics that do not identify individual users:

• country-level scan volume: where are product passports being accessed?
• time windows and frequency: when do scans cluster, without profiling an individual user?
• coarse device and language signals: enough to improve accessibility and localisation, not to fingerprint people
• access type: whether the request is for a consumer page, structured machine-readable data, or an authority-facing resource where the legal framework allows it

Public passport information should be accessible without a forced login or marketing consent. Access to restricted data requires the permissions set by the applicable product rules.

Where the law draws a hard line

How scan data may be used is a legal question. It depends on which act governs your product, Sector-specific restrictions can differ.

Detergents rules expressly prohibit usage analytics beyond what is absolutely necessary to provide the information. The clearest case today is the Detergents Regulation (EU) 2026/405. It says economic operators “shall not track, analyse or use any usage information other than as absolutely necessary for the purposes of providing online the information”. The same rule covers the digital label (Article 19(2)) and the passport itself (Article 22(h)), which also bars storing the personal data of consumers or other end-users in the passport without their explicit consent under GDPR Article 6. Other GDPR duties still apply. That is a purpose-based ban: even fully aggregated, anonymous scan counts are off-limits if you use them for market intelligence rather than simply serving the page. The applicable rules for other products must be checked separately.

Other passport regimes still require a separate privacy assessment. An absence of the same express sectoral ban is not permission to track users. Aggregated output does not show that the collection or earlier processing was anonymous or lawful. Assess the GDPR, applicable ePrivacy rules, purpose, legal basis, retention and any sector-specific restrictions before enabling telemetry.

The practical rule is to check the applicable law before enabling analytics. A DPP platform should let you disable or restrict analytics for each product group. Availability of the feature for textiles or electronics does not establish that a particular use is lawful.

Why it matters

For companies that sell through distributors, wholesalers, or cross-border channels, aggregated scan summaries can provide operational signals that other reporting channels may not reveal:

• Where are my products actually ending up?
• Which markets generate the most passport access?
• Are certain product lines scanned more often than others?
• Is there an unexpected grey-market pattern?

The aim is to monitor availability, spot unusual access patterns and make the passport easier to use, not to profile consumers. Whether this can be done lawfully depends on the actual data collection and processing.

What to look for in a provider

Not every DPP platform will offer responsible scan summaries. Some will treat the data carrier as a static link to a compliance page; others may overreach into tracking. When evaluating a provider, ask:

• Do you provide aggregated scan summaries without storing IP addresses?
• Are raw user agents, cookies, referrers and fingerprints excluded by default?
• Can sector-specific rules disable or minimise analytics where needed?
• Can I export aggregated operational data without receiving personal data?

Anomaly signals: when scan data suggests something unusual

Aggregated scan telemetry cannot authenticate a product on its own. What it can do is function as an early-warning signal for supply-chain irregularities.

Patterns worth watching:

• Scans from regions where you do not sell: if your product is only distributed in Germany and Scandinavia, but scans start appearing from Southeast Asia, that may warrant checking against your distribution records
• Sudden volume spikes: an unexpected surge of scans for a specific product line, especially from a single region, may indicate a batch diversion or another anomaly worth investigating, including possible counterfeiting
• Unusual frequency patterns: repeated access to the same product line in a short window can indicate systematic checking by a retailer, authority, distributor or unauthorised party

These signals do not prove counterfeiting on their own. A scan from an unexpected country may reflect legitimate re-export or tourist purchases, but it may also indicate grey-market diversion or counterfeit distribution. Combined with distribution records and product-line context, aggregated scan anomalies can give brand-protection teams a starting point for investigation.

Important nuance: Scan telemetry is a detection layer, not an authentication layer. It can tell you something unexpected may be happening. It cannot tell you whether a specific product is genuine. Full product authentication requires additional mechanisms: serialised identifiers, cryptographic verification or tamper-evident NFC tags. The value of scan-based anomaly detection lies in surfacing problems early, not in replacing a dedicated anti-counterfeiting strategy.

For companies in sectors with high counterfeiting risk, such as cosmetics, electronics, luxury goods and automotive parts, this capability can be one reason to invest in a DPP platform that goes beyond static compliance pages.

Product Pages That Build Trust

The problem with raw compliance

A table of material compositions, recycling codes and legal disclaimers can be difficult for consumers to understand. Clear explanations help users benefit from the information you have collected.

The alternative: branded experience

A well-designed DPP consumer view can function as a clear, branded product information page that the customer reaches while holding your product. The purpose is not to put a marketing wall in front of compliance data. The purpose is to make mandatory information understandable, trustworthy and useful.

What a branded DPP page can include:

• product story: origin, craftsmanship, sourcing choices
• certifications and trust signals: organic, fair trade, tested, verified
• visual content: product photography, video, behind-the-scenes
• brand identity: logo, colour palette, tone of voice
• sustainability narrative: carbon footprint context, circular-economy commitment

Branding is not automatically permitted merely because mandatory data remain accessible. Check the sector’s rules on additional information and separation, privacy requirements and the law on misleading commercial claims. Keep optional commercial material separate from the regulated information where required.

Reaching potential customers, not just existing ones

In many industries, you have limited control over how your product is presented at the point of sale. A retailer decides the shelf placement, the description, the context. But the DPP page is yours. If a potential customer picks up your product and scans the code in a store, they land on a page you designed, with your brand, your story and your data, without blocking access to the legally required passport information.

What to look for in a provider

• Does the platform support branded, customisable consumer-facing pages?
• Can I add visual content, logos, and brand colours?
• Is the page multilingual, matching the markets I sell in?
• Can I update content without rebuilding the data carrier?

Voluntary Services After the Sale

Optional links beyond the passport

Traditional post-sale support is fragmented across manuals, help desks, recall notices and service pages. A DPP page can make those resources easier to find, as long as the mandatory passport remains accessible without any extra step.

A DPP page can link to:

• repair and maintenance guides: extending product life and reinforcing the brand as one that stands behind its products
• recycling and end-of-life instructions: showing the consumer what to do when the product reaches end of use
• product recalls and safety updates: a public information route; direct owner notifications require a separate lawful contact channel
• voluntary product registration: clearly separate from access to the DPP itself
• loyalty programme enrolment: only after explicit opt-in, where relevant
• feedback collection: a lightweight product or service feedback form linked from the page, not required to view the passport

Why this matters commercially

Each of these interactions is currently handled through separate channels: customer service, recall notices, manuals, service portals, loyalty apps. DPP should not replace the legal privacy and consent requirements of those channels, but it can make the correct destination easier to find.

For many SMEs, that means product feedback and service signals can be connected to the same link attached to the product without turning the passport itself into a tracking layer. Clear explanations and appropriate consent arrangements can make these services easier to use.

B2B Value: Data for Partners, Not Just Regulators

DPP is often discussed as a consumer-facing or authority-facing tool. But DPP data can also be useful to business partners.

Supply-chain partners

The same structured data in a DPP can serve:

• distributors and retailers: product specifications, handling instructions, certifications
• logistics operators: packaging data, hazardous-material flags, weight and dimensions
• recyclers and waste operators: material composition, disassembly guidance, recyclability scores
• auditors and conformity bodies: declarations of conformity, test reports, traceability records

Cross-regulation efficiency

If you sell in the EU, your product data is increasingly requested by multiple regulations simultaneously: ESPR, PPWR, Battery Regulation, CSDDD supply-chain transparency, customs reform. A well-structured DPP record can serve as a shared source of product data for multiple regulatory and commercial requirements.

What to look for in a provider

• Does the platform support differentiated access levels (public, B2B, and authority-only)?
• Does the system produce structured exports that satisfy multiple regulatory frameworks?
• Can partners access dedicated data views without compromising confidential information?

How to Choose a DPP Provider That Goes Beyond Compliance

The capabilities of your provider affect how easily you can use the DPP for services beyond compliance. Here is a practical checklist of questions worth asking:

Capability	Why it matters
Privacy-preserving scan summaries	Shows operational patterns without profiling consumers
Branded consumer pages	Makes mandatory product information clearer and more trustworthy
Multilingual support	Essential for cross-border products: consumers expect their language
Updatable content	You should be able to update the page behind the code without reprinting
Differentiated access	Public, B2B, and authority layers: not everything is for everyone
Data export and portability	You own the data: you should be able to take it with you
No vendor lock-in	Open standards (GS1 Digital Link), portable identifiers, no proprietary exit traps
Voluntary service links	Repair guides, recall channels, opt-in loyalty, lightweight feedback forms

Not every provider will score well on all of these. Use these questions to compare providers against your actual needs.

The Early-Mover Advantage

Why starting now matters

Companies that build their DPP infrastructure before mandatory deadlines have more time for testing and operational learning.

If you start testing DPP workflows before mandatory deadlines, by the time the first major obligations arrive you will have months or years of experience with data collection, labels, resolver behaviour, translations, supplier evidence and consumer-facing content. That experience can reduce last-minute work.

Building practical experience

Early preparation gives you time to test your DPP processes before the applicable deadline. Starting early can help you:

• test and improve your consumer pages
• understand which products generate passport access and where the operational questions appear
• build internal processes for data collection and updates
• establish processes for collecting supplier data
• practise presenting useful product information in your brand style while protecting users’ privacy

This leaves time to resolve problems before the deadline.

FAQ: Frequently Asked Questions

Does the ESPR regulation itself require analytics or marketing features in DPP?

No. ESPR does not require analytics or marketing. Access to public mandatory information must remain direct; restricted data remains subject to the applicable access rights. Detergents Regulation (EU) 2026/405 prohibits tracking or analysing usage except where absolutely necessary to provide the information online.

Is scan analytics GDPR-compliant?

Not automatically. Aggregation and avoiding stored IP addresses are useful safeguards, not proof of compliance. Personal data may be processed before aggregation. The legal basis, collection method, purpose, retention and applicable ePrivacy and sector rules must be assessed. Under Regulation (EU) 2026/405, usage processing is limited to what is absolutely necessary to provide the information online.

Can I update the content behind a data carrier after printing?

Yes, if your DPP infrastructure uses resolver-based identifiers like GS1 Digital Link. The data carrier points to a URL, and the content behind that URL can be updated without changing the physical code. This is essential for recall updates, service information, repair guidance and regulatory changes.

Will consumers actually scan product codes?

There is no universal, publicly documented scan-rate benchmark for DPPs. Adoption varies by sector, product and market, so consumer scanning should be treated as a testable opportunity rather than a guaranteed outcome. Run a pilot, measure the response lawfully for the relevant sector, and make the page useful enough that a scan provides real value.

Can a single data carrier serve both DPP compliance and marketing?

Potentially, subject to the product rules, privacy law and any restrictions on additional information. Technical support for several destinations does not itself authorise marketing. Mandatory DPP access must remain direct and optional commercial services separate.

Read Next

• What Is a Digital Product Passport?
• How to Create a DPP: Step-by-Step Guide
• DPP Data Requirements: What Data You Actually Need
• GS1 Digital Link for DPP
• DPP Service Provider Requirements Explained

Official Sources

• ESPR Regulation (EU) 2024/1781
• European Commission: Ecodesign for Sustainable Products
• GDPR / (EU) 2016/679
• ePrivacy / 2002/58/EC
• (EU) 2026/405, Articles 19, 22

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