The Regulation for My Sector Is Not Yet Defined: Is It Better to Act Now or Wait Until Everything Is Clear?
This is the most important question of all — and the one most often postponed by manufacturers, importers, and supply chain decision-makers. The short answer is: it is better to act now. But first, it is important to understand why waiting for the Delegated Act is a less safe strategy than it may seem for companies preparing for Digital Product Passport implementation and ESPR compliance.
The Misconception of “Let’s Wait for the Delegated Act”
The idea that preparation can begin only once the specific regulation for your sector is released seems logical — but it has a structural flaw. Building a data infrastructure suitable for the DPP takes time: time to map the real supply chain, to structure internal data governance processes, to involve suppliers, and to select and test technological solutions with interoperable EU standards. It is not something that can be completed in a few weeks.
When it arrives, the Delegated Act will grant a minimum transition period before the obligation becomes effective. But that period is intended for adaptation — not for starting from scratch. Those who begin only once the regulation is published will be forced to rush through what could have been done methodically, risking decisions that will later be costly to correct.
It is also worth adding a point of honesty: we do not know with certainty how demanding the initial DPP requirements will be. Delegated Acts may allow a gradual start with a limited set of mandatory data, or they may require a higher level of detail from the outset. No one can say for sure today. And it is precisely this uncertainty that makes the available time valuable — not an opportunity to wait, but to explore, test, and build Digital Product Passport capabilities without the pressure of deadlines.
The DPP Is Already Useful Today — Even Without a Delegated Act
There is an aspect that rarely emerges in discussions about the DPP, yet is strategically relevant: even without a specific obligation for your sector, the DPP is already an efficient tool for complying with other horizontal European regulations that are already in force or coming into effect.
A concrete example is Regulation (EU) 2025/40 on packaging and packaging waste — the so-called PPWR (Packaging and Packaging Waste Regulation). This regulation imposes strict Ecodesign criteria to ensure that all packaging is recyclable or reusable by 2030, requires companies to demonstrate the use of recycled materials, and is accompanied by a directive on environmental claims that requires scientific verification of any ecological statement before it is communicated.
The PPWR does not explicitly require a DPP — but the guarantees it demands must be demonstrable, verifiable, and transferable to both the market and regulatory authorities.
This is exactly what a well-designed DPP does: it collects, structures, and makes accessible reliable information on product composition, material origin, and environmental characteristics. A company that builds its DPP data infrastructure today with a DPP mindset is not only preparing for its future Delegated Act — it is also equipping itself with the most effective tool to comply with the PPWR, the Environmental Claims Directive, and all other horizontal EU regulations that converge toward the same goal: making what is declared verifiable.
What Can Be Done Concretely Today
The first useful action is diagnosis. There is no need to wait to know exactly which data the regulation will require in order to understand what data is currently missing. The general structure of the DPP is already known: product composition, material origin, environmental footprint, durability, reparability, circularity, and supply chain traceability. Mapping the gap between what is already known and what should be known is something that can be done now.
And almost invariably, this mapping reveals that the data exists but is scattered across ERP systems, laboratories, suppliers databases, and paper documents — and that organizing it requires time that would be a mistake not to start investing now.
The second action is to map the real supply chain — not the one described in contracts, but the actual one, including second- and third-tier suppliers where known. This is work that does not expire and will be useful regardless of what the regulation ultimately requires.
The third is to learn from sectors that are already implementing the DPP — such as batteries and textiles — by observing the real operational challenges they are facing and drawing lessons at no cost.
The regulation for your sector is not yet in place. But the time to prepare is passing anyway — and other European regulations, starting with the PPWR, are not waiting for anyone. Every month available today is worth far more than any month under pressure after the publication of the Delegated Act.
