Step 9
SME corner
Small and medium-sized enterprises face the same compliance obligations as larger firms, but with fewer resources. The ESPR and most sector regulations provide proportionate pathways. Use them.
Built-in proportionality
- Extended deadlines. Most delegated acts set later applies-from dates for SMEs and micro-enterprises.
- Simplified formats. Template DPPs with a narrower data-point set are expected for small producers in several sectors.
- Exemptions for destruction-of-unsold-goods rules under ESPR apply to micro and small firms.
- Simpler due-diligence. The Battery Regulation's Art. 48 simplifies supply-chain due diligence for SMEs.
Shared infrastructure options
Most SMEs do not need to build a resolver or a Verifiable Credentials service. Use shared infrastructure:
- Industry-association DPP services (common in textiles, furniture, chemicals).
- Chamber of commerce digital passport pilots.
- Open-source reference implementations (CIRPASS, Tracifier) hosted by a service provider.
- GS1 Digital Link resolvers offered by national GS1 member organisations.
Funding to actually use
- EIC Accelerator — for SMEs building DPP-enabling products or services.
- Digital Europe Programme — SME calls. Direct grants for digital adoption.
- Enterprise Europe Network — free advisory and match-making for EU compliance and funding.
- National Recovery and Resilience Plans — many include circular-economy envelopes dedicated to SMEs.
Practical advice
- Start from the applicable delegated act, not a vendor pitch.
- Pilot one SKU end-to-end. Do not try to boil the ocean.
- Use your GS1 prefix and a shared resolver. Avoid custom domains for DPP URLs until your volume justifies it.
- Join the Foundation's SME working group to share templates and negotiating power.