Does the DPP Automatically Protect Us from Accusations of Greenwashing — or Is It Just Additional Bureaucracy?
Neither — but the truth requires a distinction that few make, and which is essential to understand what can be expected from this tool and what cannot within the broader framework of Digital Product Passport compliance, ESG transparency, and EU sustainability regulations.
What Really Changes with a Regulated DPP
Greenwashing thrives in the absence of verifiability, traceability, and standardized sustainability data. As long as sustainability claims remain voluntary, generic, and without shared standards, anyone can write “eco-friendly” on a label without having to prove anything to anyone. The market is unable to distinguish those who are serious from those who are not — and this penalizes precisely the companies that are truly investing.
The DPP regulated under ESPR regulation changes this logic structurally. The information it contains is not chosen at the company’s discretion: it is defined by Delegated Acts, with mandatory content, standardized formats, and declarations that carry a traceable digital signature. It is no longer possible to choose to highlight only the positive aspects and omit the inconvenient ones — at least for the data explicitly required by regulation. Every declaration included in the passport is a legally relevant statement: declaring it falsely is no longer just a reputational issue, but a legal and regulatory compliance issue.
In this sense, a compliant and properly completed DPP is objectively a shield against certain forms of greenwashing — those relating to the mandatory data required by regulation for that product category. It is worth adding that even additional voluntary declarations that the manufacturer chooses to include in the passport beyond the minimum requirements are cryptographically signed under their legal responsibility: it is not possible to include them and then deny them without consequences.
The Limitation No One Mentions: When the DPP Is Not Yet Mandatory
The protection described above fully applies to sectors where the DPP is already mandatory under the relevant Delegated Acts. The situation changes significantly for all sectors where the DPP is not yet mandatory. Here, a space opens up that is already today — and will likely grow in the coming years — fertile ground for what we can call passwashing: the practice of creating digital passports that simulate transparency without guaranteeing it.
As the DPP becomes a recognizable digital compliance tool and is perceived as a guarantee by the market, the temptation to exploit its form without respecting its substance increases: selectively chosen sustainability data, omission of critical information, QR codes that lead to static web pages controlled exclusively by the company, without any independent verification mechanism.
In this context, partial but relevant protection comes from EU Directive 2024/825 on Consumer Empowerment for the Green Transition. This directive — distinct from ESPR but complementary to the Digital Product Passport framework — explicitly prohibits generic or unverified environmental claims, imposes greater transparency on durability and reparability, and introduces harmonized labels and notices for uniform sustainability communication. It is a regulatory tool that combats greenwashing even in sectors not yet covered by Delegated Acts, reducing the space for the most clearly unfounded claims.
However, a grey area remains: for all information that does not fall under the obligations of Directive 2024/825 nor those of any applicable Delegated Act, some companies may continue not to be fully transparent. This grey area will gradually shrink as different product categories become covered by their respective Delegated Acts requirements — but in the meantime, it remains a real risk, both for consumers and for companies that are seriously investing in sustainability, supply chain transparency, and ESG compliance while competing in an uneven playing field.
Real Protection: The Conditions That Make the Difference
A Digital Product Passport (DPP) truly protects against greenwashing only when certain conditions are met. The data must be those actually required by the Delegated Acts, not an arbitrary selection. The declarations must be based on real measurements — not generic estimates taken from industry databases when primary data is available. The DPP system must ensure that once data is entered, it cannot be altered at will. And ideally, there must be an independent verification mechanism, at least for the most critical environmental and supply chain data.
When all these conditions are met, the DPP stops being bureaucracy and becomes something much more powerful: verifiable proof that what is declared corresponds to reality. Not storytelling, but story-proving. And in a market where everyone claims to be sustainable, the ability to demonstrate it with traceable data is a genuine competitive advantage — not just a legal safeguard.
The DPP is not an automatic shield against greenwashing: it is a tool that, if used correctly, makes greenwashing structurally more difficult and more risky. The difference between real protection and false security depends on how the DPP system is built — and on whether the regulation already makes it mandatory for your sector.
