Q&A with Megan Brewster, Impinj
- Let’s start with the basics – what exactly is the ESPR working plan, and why should brands and supply chain leaders care about its release on April 16 ?
Put simply, the Ecodesign for Sustainable Products Regulation (ESPR) is the legal framework set in place by the European Commission to establish ecodesign requirements. It’s the cornerstone of the European Union’s (EU) effort to reduce the environmental, energy, and climate impacts of products and energy consumption, and to improve circularity.
One element of this framework is the Digital Product Passport (DPP) legislation, which is the digital record containing key information about a product’s composition, origin, and lifecycle. Companies selling products in Europe will need to collect and share detailed data on an item’s verified sustainability attributes. 
The ESPR Working Plan, which was published April 16th, outlines the implementation timeline for DPP product categories over the next five years. Now that it is published, the countdown to compliance has begun for those selling products in the target categories to the EU market.
- How does the Digital Product Passport (DPP) framework intersect with Impinj’s vision for RAIN RFID and item-level visibility?
At its core, the Digital Product Passport framework is about collecting comprehensive, granular data about a product across its entire lifecycle to generate transparency, consumer safety, and responsible use and disposal of that product.
This is where RAIN RFID truly shines, offering item-level tracking throughout the supply chain and beyond. RAIN RFID’s robust lifecycle tracking capabilities not only satisfy compliance requirements but also solve other business challenges. Today, RAIN RFID helps companies automate their supply chains, combat counterfeiting, and support circular business models.
Companies integrating RAIN RFID into their DPP readiness plans can stay ahead of mandates while modernizing their operations and unlocking more sustainable fulfillment models for their future.
- As regulatory momentum builds in the EU and beyond, how prepared are global brands for DPP requirements – and what are the biggest blind spots you’re seeing?
A recent survey of retail supply chain professionals from Impinj revealed that retailers may have their work cut out for them. About half (49%) were concerned about their organization’s ability to meet DPP requirements, while over one-third (37%) of respondents don’t expect to meet the DPP deadline.
It’s important for retailers to understand that even though DPP originates in Europe, anyone selling into the European market in the target product categories will need to comply with the regulation.
- Can you give us a real-world example of how RAIN RFID is already helping organizations meet or exceed what the DPP mandates will require?
RAIN RFID is in use at every stage of the product lifecycle. In manufacturing, RAIN is used to track assets, while tire makers are embedding RAIN tags in tires to help monitor status, track mileage, and manage maintenance schedules.
In logistics, RAIN RFID helps enterprises verify shipments and pallet builds, authenticate goods, and automate track and trace processes.
In retail stores, retail brands use RAIN RFID to speed up inventory management, giving retailers a clear picture of available inventory and ensuring shelves are stocked. The item-level visibility helps retailers sell down to the last item and improve forecasting so they only make as much inventory as they can sell. Overproduction is a huge issue in retail, and as they say, the most sustainable products are those that are never made.
- What’s the strategic significance of traceability at the item level – and how does that evolve when you start talking about sustainability, circularity, and compliance?
Item-level traceability is a game changer for supply chains because it gives companies real-time visibility into each individual product. With digital identifiers enabled by technologies like RAIN RFID, you can track inventory with pinpoint accuracy, which helps reduce overproduction, minimize waste, and improve efficiency. For example, some companies have cut excess inventory by over 70%, and food producers have extended shelf life by nearly a week—just by having better data. This level of detail is crucial not just for operations, but for building more resilient and responsive systems overall.
It really gets interesting when you layer on sustainability, circularity, and compliance. Traceability becomes the foundation for circular models—like enabling product resale, recycling, or reuse—because you know exactly where each item has been and what it’s made of. It also makes regulatory compliance much easier, especially with initiatives like the EU’s Digital Product Passport, which require detailed product histories. So traceability isn’t just a supply chain tool—it’s becoming a strategic enabler for sustainability and long-term brand value.
- How do you see the ESPR working plan impacting supply chain digitization priorities in the next 12-24 months?
With last week’s publication of the ESPR working plan, we now know that textiles are the top-priority product category for Digital Product Passports and that their timeline for implementation is 2027. (Previously, the European Commission announced numerous product categories but did not specify the order in which they would be mandated or by when.) This means that retailers and brands selling textile items in the European Market should start preparing now for implementing Digital Product Passports on these items.
After textiles in 2027, the next top-priority product categories are not far behind—implementation for tires also begins in 2027, followed by furniture in 2028 and mattresses in 2029.
Interestingly, the European Commission has chosen to exclude footwear from this initial timeline for implementation, opting instead to conduct a study on this product category and then provide an update at a mid-term review in 2028. Other product categories that were originally flagged for DPPs but are not yet in the working plan—and thus likely to be considered after 2030—include detergents, paints, lubricants, and chemicals.
- What are the most common misconceptions about DPPs and what they’re designed to do?
One of the biggest misconceptions about DPPs is that they’re just a fancy version of a label or QR code—basically, a static record of what’s in a product. In reality, DPPs are dynamic, digital tools that carry rich, evolving data about a product’s entire lifecycle. DPPs enable transparency across supply chains—from raw materials all the way to reuse or recycling—so the value goes beyond the data itself, and now includes the ability to update and share that data across multiple stakeholders.
Another common misunderstanding is that DPPs are just about compliance. While they do support regulatory requirements—especially in the EU—they’re actually a powerful enabler of circularity and business innovation. Companies that embrace DPPs early can unlock new models like product-as-a-service, resale programs, and more efficient recycling systems. So rather than seeing them as a burden, the most forward-thinking companies see DPPs as a chance to differentiate and future-proof their supply chains.
- What role can emerging tech like AI or digital twins play in accelerating DPP readiness when combined with RFID infrastructure?
One of the key benefits of AI is its potential for speed and scale, characteristics that are paramount for achieving meaningful DPP outcomes. However, the outputs from any AI tool are only as good as the data inputs. Effective AI strategies are built on accurate data. According to recent Impinj data, 43% of supply chain managers, including those in retail, indicated that data accuracy is a top challenge within the supply chains they manage.
The promise of RAIN RFID — a passive, battery-free wireless technology — is its ability to reliably deliver accurate, item-level data about every item in a retailer’s supply chain. And it does this in an affordable way that enables the scale retailers need, connecting each unique RAIN RFID identifier to an item’s digital twin. The use of digital twins ensures that data about a product’s entire lifecycle, from the materials it comprises to every transfer of ownership and its end-of-life instructions, can be maintained and accessed by authorized entities.
- How does Impinj support its customers not just technologically, but strategically – as they shift from compliance thinking to opportunity thinking around DPPs?
Businesses should take a long view and recognize that what happens in the E.U. often makes its way to the U.S. and beyond. If retailers are already investing in DPP compliance for the E.U. market, then it makes sense to plan for similar regulations in every market. As the DPPs progress, we at Impinj have offered technical guidance and acted as a trusted advisor to enterprises looking to develop their strategic approach to DPP compliance and identify opportunities beyond compliance.
The true opportunity for retailers, regardless of their geographic location, is to get a lead on engaging with their customers meaningfully. For example, consumers are already committed to making sustainable purchases, a preference that is likely to only deepen over time. Those retailers who capture this opportunity early will earn long-term preference from shoppers who increasingly prioritize sustainable shopping.
- If you’re a brand or manufacturer reading this and haven’t started preparing for DPP compliance – what’s step one? And what’s the cost of waiting?
Retailers can and should start preparing now for the anticipated 2027 adoption timeline for textiles. First, they should identify an internal expert or trusted consultant to take responsibility for tracking DPP legislation as it progresses. They should then outline their Digital Product Passport strategy based on their organization’s specific products and needs. This includes understanding DPP data collection requirements and evaluating systems and technologies that will help their organization achieve DPP compliance. Importantly, when considering potential data carriers, whether it’s RAIN RFID or something else, retailers should ensure their operations and technical teams are working closely with sustainability teams. Completing this critical strategic work well before the compliance deadline for textiles will help ensure retailers don’t fall behind.
Megan Brewster is VP of Advanced Technology at Impinj.
Photo by quokkabottles on Unsplash
