Digital Product Passport Cost for SMEs: Where It Goes

On 4 November 2026 Amazon published a summary of a study it had commissioned from the consultancy Oxera: Why the Digital Product Passport risks failing small firms, and how to fix it. The full report, Assessment of costs associated with enabling Digital Product Passports in the EU, is dated 2 November 2026 and is public as a PDF on oxera.com.

Its main finding: small and medium-sized enterprises and less digitally mature firms are likely to face relatively higher compliance costs. Amazon paid for the study, and its numbers come mostly from interviews and from a sector study on detergents, so they are indications, not a market survey. They still give a small brand a useful picture of where the effort sits.

How much does a digital product passport cost for an SME?

Oxera splits DPP costs into categories and collects the estimates available for each (section 4.7 of the report). Most come from a handful of interviews, which the report itself says is limited evidence.

Cost item	Estimate in the Oxera report	Basis
Labelling	Low where the passport works at the labelling level a firm already uses, for example SKU; costly if labelling lines must be reconfigured	Interviews, no general range
DPP software development	Likely modest for smaller firms with simple systems; €150,000 to €500,000 one-off for larger firms	Interviews
External DPP service	Around €2,000 to €3,000 a year; some providers run freemium models	One interview
Data preparation and traceability	Around €50,000 a year for a medium-sized European fashion company, plus around €25,000 a year for environmental performance data	Interviews
Initial data assembly	A few thousand euros for small firms, €50,000 or more for large firms	Interviews
Staff	0.5 to 5 extra full-time positions per company in the detergent sector, about €50,000 to €500,000 a year	Detergent sector study (IKW)
Implementation consulting	Around €30,000 to €50,000 on average, one-off	Interviews

Oxera's own conclusion is that ongoing platform fees are unlikely to be the main cost burden. The one-off work to set up the data and the operating model can be substantial, and staff effort is the most consistent cost across its sources.

Why is supplier data the expensive part?

Oxera quotes a split given at the World DPP Summit in Berlin in March 2026, where a representative from Sika estimated that about 90% of total DPP effort goes into data preparation, followed by publication (5%), maintenance (3%) and archival (2%). The interviews for the report pointed the same way: collecting, structuring, validating and preparing data were the main cost drivers.

These costs hit small firms harder for two reasons. Most of them are fixed: one industry estimate cited in the report puts fixed costs at more than 90% of total implementation spending, and spread over a smaller output they mean a higher cost per unit. They also grow with the supply chain. Long, multi-tier, globally dispersed chains mean data has to come from more upstream actors, often with uneven digital capabilities. Oxera names textile and fashion as a clear example: products combine several materials sourced through global, multi-stage chains, which creates many data points and verification steps.

For textiles, the report also notes that the data field requirements are not legally defined yet.

Factory data and whole-garment data: the denim case

A case published the same week shows what "data preparation" means in practice. In a white paper called "The Denim Passport", EIM by Jeanologia and BCome compared a conventional finish (stone wash and potassium permanganate spray) with Jeanologia's ATMOS technology on a 100% cotton denim garment, as reported by Apparel Views on 5 November 2026. EIM measured water, energy and chemicals on the factory floor, and BCome fed those measurements into a life cycle assessment following the EU Product Environmental Footprint (PEF) method.

At the factory step, water consumption fell 96.3%, energy 20.8% and process emissions 38.2%. Across the life cycle of the whole garment, global warming impact fell 1.99%, water scarcity 1.18% and marine eutrophication 9.88%.

Both sets of numbers are correct, but they cover different boundaries: one process step, or the whole life of the garment. A figure in a passport means little without the method and boundary behind it, and measured supplier data says more about a specific product than a sector average. As BCome's co-founders put it in the article: "The quality of a DPP depends on the quality of the data that feeds it."

What Oxera asks the European Commission

The report closes with policy recommendations. They include applying passport requirements proportionately, reflecting differences in firm size and digital maturity in timelines and requirements, giving regulatory certainty early, and promoting common data standards and interoperable formats. The standardisation point targets the data side directly: according to the report, common standards and interoperable formats reduce the cost of collecting, exchanging and integrating DPP information.

When do textile products need a digital product passport?

Not yet. The Ecodesign for Sustainable Products Regulation (EU) 2024/1781 sets the framework, and product rules come through delegated acts. The European Commission's textile and apparel DPP page lists the planned adoption of the textile delegated act in Q4 2027. A transition period follows, so obligations for textiles are expected from 2029 at the earliest.

Batteries are the exception with a fixed date: from 18 February 2027 each EV battery, LMT battery and industrial battery above 2 kWh placed on the EU market needs a battery passport (Regulation (EU) 2023/1542, Article 77).

What should a small fashion brand do before 2029?

Given where the Oxera numbers put the effort, the first steps are about data:

Map your suppliers. List who makes what, at which tier, and who can send primary data today.
Ask for specific fields. A short request for named values (fibre composition, country of each process step, measured water and energy where available) gets answers. "Send us everything" does not.
Keep the method with the number. Record whether a figure is measured or a sector average, and on which boundary, as the denim case shows.
Name one data owner. Staff time is the most consistent cost in the report, so make one person responsible for the product data.
Keep labelling simple. Labelling costs stay low where the passport fits the labelling level you already use. Check the granularity in the delegated act once it is published before you change any production line.

Our guide to digital product passport software for clothing makers covers how to choose a tool once the data side is in order, and our fashion DPP page sums up the textile rules.

Hoken Pass is digital product passport software for SMEs. On our pricing page (checked on 6 November 2026) the Free plan costs €0 with 3 passports and Base costs €120 a year with 8 passports. Each published passport gets a qualified eIDAS timestamp. For battery passports, a brand can send a supplier a link that opens without an account and shows only the fields the brand asks for, then accept the answers point by point. Our article on battery passport supplier data covers which battery data usually comes from suppliers.

Frequently asked questions

How much does a digital product passport cost for a small business?

There is no single figure yet. In Oxera's report of 2 November 2026, external DPP service fees were estimated at around €2,000 to €3,000 a year in one interview, while data preparation and traceability for a medium-sized European fashion company were estimated at around €50,000 a year. The report concludes that platform fees are unlikely to be the main cost.

What is the most expensive part of a digital product passport?

Data preparation. A representative from Sika, quoted in the Oxera report, estimated at the World DPP Summit in March 2026 that about 90% of total DPP effort goes into data preparation, against 5% for publication, 3% for maintenance and 2% for archival.

Why do digital product passports cost small firms more?

Most implementation costs are fixed, so a firm with lower output pays more per unit. Smaller and less digitally mature firms may also need to invest in digital capabilities first, and long supply chains, as in textiles, add supplier engagement and verification work.

When will textile products need a digital product passport?

The European Commission plans to adopt the ESPR delegated act for textiles in Q4 2027. Obligations follow after a transition period, so they are expected from 2029 at the earliest. The data fields are not legally defined yet.

Who paid for the Oxera study on digital product passport costs?

Amazon commissioned the study, and Oxera prepared it. The report is dated 2 November 2026 and Amazon published a summary on 4 November 2026.

Sources

Start free with 3 passports: hokenpass.com.