Who Has the Most Power - Brussels or Zalando?
Or perhaps you’re struggling to get the C-suite to understand the urgency of change? Look no further—Zalando has just delivered one of the most compelling arguments.
For many brands, compliance strategies are built around the regulatory requirements of each market they sell in. Then, there’s Zalando - an e-commerce giant so influential that it’s like its own country, its own market, with rules that brands must cater to if they want a place on its platform.
The Zalando SE Quality Assurance Manual is a comprehensive and practical guide for ensuring product, labeling, and packaging compliance. With its 2025 V10 version, Zalando is looking at current requirements, but it also provides guidance for preparing for future regulations. At the core of these updates is the Digital Product Passport (DPP).
What is the Digital Product Passport (DPP)?
The DPP is designed to promote transparency, enable responsible consumption, and share vital product information across the entire value chain. Think of it as a “digital twin” for every product - an online database providing detailed, structured information for everyone involved, from producers and retailers to consumers, repairers, and recyclers.
Zalando’s V10 manual outlines key features of the DPP under section 3.2.5. Here’s the essential information that could be included in the DPP (note, this is not an exhaustive list):
- Unique product identifier
- Substances of very high concern (SVHCs)
- Product performance information
- User instructions
- Global Trade Identification Number (as per ISO/IEC 15459-6, or equivalent)
- Relevant commodity codes, such as TARIC codes
- Compliance documentation, including declarations of conformity and technical details
- Manufacturer/importer details
- Facility identifiers relevant to the product.
Although the DPP is not yet required, it is expected to become mandatory by 2027. Brands won’t be able to market products in the EU without a valid DPP in place. Early preparation will be critical to ensure compliance by the time the regulation takes full effect.
Updates in Zalando’s V10 Manual regarding DPP
The V10 manual incorporates several crucial updates compared to V9, aligning expectations with the European Commission’s ESPR timeline and delegated acts on textiles. For instance, the initial projection had DPP requirements coming into force in 2026, but the timeline has now been revised to 2027.
For brands still struggling to get buy-in from leadership on the need to invest in DPP compliance now, Zalando’s guidance is a powerful motivator. Leadership might dismiss regulatory updates from Brussels as “mumbo-jumbo,” but when Zalando explicitly integrates these requirements into its manual, it becomes clear that non-compliance means exclusion - not just from Zalando, but perhaps the EU market entirely. Trust us, this is an attention-grabber for decision-makers.
What Will DPP Compliance Require?
When the DPP requirements are enforced, one of the primary steps will involve registering Unique Product Identifiers (UIDs) within the EU’s DPP Registry, managed as part of the European Commission’s central service.
Brands will either need to become DPP service providers themselves or collaborate with third-party providers, such as Trimco Group and Kezzler, to input UIDs into the central registry.
Zalando has already listed 9 of the expected 15 DPP data elements needed by 2027. While future iterations are likely to include more advanced requirements, Zalando’s guideline gives brands clarity on which baseline features to tackle immediately.
Challenges and Solutions for Brands
We do not know the level of details the delegated act for textiles will demand of the DPP. WIll it be SKU level or Serialized. To be able to capture the R-use cases and return on investment it is most likley brands will opt for serilzation anyway. For brands, serialization - the process of assigning unique IDs to individual products – seems to be one of the biggest hurdles in adopting the DPP system. This requires rethinking operational mechanisms for product labeling, especially for serialized labels on garments.
Thanks to partnerships like Trimco Group and Kezzler, solutions are already being built for compliance . Trimco Group’s collaboration with Kezzler utilizes technologies like the GS1 digital link, which is also backed by the CIRPASS consortium as a suggested approved DPP solution. These dynamic QR codes allow brands to embed required data directly into the product’s label while leaving flexibility for future updates.
Trimco Group has proven its capability in this area through successful collaborations with brands lHolzweiler. These systems ensure that once a product’s UID is registered in the central DPP registry, it can enter both the EU market and Zalando’s platform seamlessly.
Beyond Compliance - Added Benefits of DPP Adoption
Another compelling feature of Trimco and Kezzler’s partnership is the ability to add new data elements dynamically. The QR codes integrated with their system can evolve over time, “living” with the garment and updating as more information becomes available. This adaptability makes compliance a living, breathing process rather than a static one - and it adds layers of value to the end consumer experience.
Zalando has taken the DPP from a distant regulatory challenge to an immediate, actionable priority for brands. By doing so, it’s given traceability and ESG teams a concrete resource to rally leadership and action within their organizations.
For any brand working towards DPP compliance, the message is clear: Prepare now, invest in the right technologies, and align your processes with Zalando’s leadership.