ESPR and Small Textile Brands: Are SMEs Exempt from the Digital Product Passport?

One of the most common questions from small and medium-sized textile businesses is whether the EU's Digital Product Passport requirement applies to them. The short answer: there is no blanket SME exemption from the ESPR. But the regulation does include provisions that affect how and when small brands must comply. This article explains what those provisions actually mean.

What the ESPR Framework Actually Says About SMEs

The ESPR Regulation (EU) 2024/1781 includes explicit language requiring the European Commission to consider the impact on SMEs when drafting delegated acts for each product category. Article 5 of the ESPR states that delegated acts should "take into account the needs of SMEs" and avoid placing disproportionate administrative burdens on small operators.

Critically, this is an instruction to the Commission about how to design requirements — it is not an exemption from the requirements themselves. The ESPR does not contain a size threshold below which DPP obligations disappear entirely.

The Micro-Enterprise Distinction

The ESPR does allow delegated acts to exempt micro-enterprises from specific requirements. Under EU definitions, a micro-enterprise has:

• Fewer than 10 employees, AND
• Annual turnover or balance sheet total not exceeding €2 million

Whether micro-enterprises in textiles will receive a full or partial DPP exemption depends on the textile delegated act — which had not been finalised as of early 2026. However, even if an exemption is granted to micro-enterprises, it is unlikely to extend to small enterprises (10–49 employees) or medium enterprises (50–249 employees).

Most textile brands exporting to the EU — including small labels, private-label suppliers, and growing DTC brands — exceed the micro-enterprise threshold or will not be protected by any exemption even if one exists.

The Indirect Requirement: Supply Chain Pressure

Even if a small brand technically qualifies for a future micro-enterprise exemption, it may face DPP requirements through a different channel: its retail buyers.

Major EU retailers — department stores, fashion chains, marketplaces — are incorporating DPP capability into their supplier requirements. A small brand supplying to a large retailer will be asked to provide a product-level QR code and structured DPP data regardless of its size, because the retailer is subject to ESPR and needs compliant data from its supply chain.

This means the practical exemption threshold for small brands is often lower than the regulatory threshold: if you sell to a compliant retailer, you effectively need a compliant DPP.

What "Simplified DPP" Might Mean for Small Brands

The Commission may introduce tiered or simplified DPP requirements for smaller operators. This could mean:

• A reduced data set (fewer mandatory fields than large enterprises)
• Longer transition periods before full compliance is required
• Batch-level (rather than unit-level) serial numbers — fewer QR codes to generate

epassportify already supports both batch-level and unit-level serial generation. Small brands can start with batch-level QR codes (one code per production run rather than one per item) and scale to unit-level as needed. This flexibility means the platform adapts to whatever requirement level the delegated act eventually specifies.

The Practical Risk of Waiting for Clarity

Some small brands are tempted to wait until the textile delegated act is published before taking action. There are two problems with this approach:

1. Data collection takes time: Building the material composition, supply chain, and certification data for your product range is not something that can be done in days. The more products you have, the longer it takes. Brands that start now build this data set incrementally — without the deadline pressure.
2. Buyer requirements don't wait: As noted above, commercial DPP requirements from retailers are arriving ahead of the regulatory deadline. A small brand that cannot provide a structured DPP when a buyer requests it is at a competitive disadvantage — even if no regulation technically required it yet.

How Small Brands Can Start Without Over-Investing

epassportify is designed for exactly this scenario — brands that need to start building DPP-ready data now, without committing to a complex enterprise implementation:

• Start with your top-selling products: You do not need to passport your entire catalogue on day one. Enter your five or ten most important SKUs, generate their QR codes, and test the public DPP page with a buyer or auditor.
• Use the 4-step wizard: The wizard guides you through each field — Basic Info, Materials, Supply Chain, Compliance — in a structured way that ensures nothing is missed. No data architecture expertise needed.
• Generate QR labels immediately: Once a product is entered, you can generate serial numbers and download a PDF label sheet the same day. The QR codes work from day one.
• Add products gradually: As your compliance data improves — new certifications, updated supply chain records — add them to the platform at your own pace.

Conclusion

There is no confirmed blanket exemption for small or medium-sized textile brands under the ESPR. Micro-enterprises may receive relief in the textile delegated act, but most SMEs will be subject to DPP requirements — either through direct regulation or through commercial buyer pressure. The most practical approach is to begin building structured DPP data now, starting with your most important products, so that compliance is a natural evolution rather than a last-minute scramble.