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Digital Product Passport (DPP) service providers

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In the context of the Ecodesign for Sustainable Products Regulation (ESPR) the digital product passport (DPP) has been introduced as a tool to provide easy access to digital information related to products' sustainability, circularity, and legal compliance. This Delegated Act will establish rules on the operation of DPP service providers, an essential component of the wider DPP governance.

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Public consultation

ID: 14382

Lobbying Activity

60 responses

European Automakers Demand Control Over Digital Product Passport Services

Association des Constructeurs Européens d'Automobiles, 10 Dec 2024

ACEA wants flexibility to manage passport systems themselves rather than using external providers. They demand input on service content, terms, specifications and costs, and question why backup data must be shared with third parties when internal copies are possible.
This would let them avoid external service provider fees and maintain control over their data.
Independent service providers lose potential revenue from mandatory backup and hosting services.

Consultation response

EuroCommerce, 10 Dec 2024

EuroCommerce welcomes the opportunity to contribute to the European Commissions impact assessment on the delegated act for Digital Product Passport (DPP) service providers. As a forward-looking tool for enhancing transparency and sustainability, the DPP has the potential to modernize consumer…

Consultation response

DIGITALEUROPE, 10 Dec 2024

Executive summary The Delegated Act on rules for DPP service providers presents a critical opportunity to establish a framework that is both effective and pragmatic. Open and constructive dialogue with industry will key moving forward to shape a framework that meets regulatory goals, reduces…

Consultation response

Confederation of Finnish Industries EK, 10 Dec 2024

Digital Product passport rules for service providers The Confederation of Finnish Industries EK thanks for the possibility to comment on the call for evidence concerning the Digital Product Passport rules for service providers. This delegated act will set out the framework for DPP services.…

Consultation response

BASF SE, 10 Dec 2024

BASF supports the key objectives of the Digital Product Passport in ESPR, particularly those aimed at addressing the shortcomings of the current rules, enhancing the sustainability of products, and contributing to the European economys green and digital transition. This aligns with BASFs new…

Consultation response

Orgalim – Europe's Technology Industries, 9 Dec 2024

Please refer to the attached paper.

Consultation response

Robert Bosch GmbH, 10 Dec 2024

- The delegated act is welcomed as further clarity on the role of digital product passport service providers (DPPSP) is needed for legal certainty of affected economic operators. Requirements set out in Art. 10 and Art. 27 of the ESPR must be unambiguously speci-fied through secondary legislation…

Consultation response

Technology Industries of Finland (Teknologiateollisuus ry), 10 Dec 2024

Technology Industries of Finland appreciates the opportunity to provide early feedback on the upcoming delegated regulation that defines the requirements for digital product passport (DPP) service providers. Recommendations for the upcoming delegated regulation defining requirements for Digital…

Consultation response

Verband Deutscher Maschinen- und Anlagenbau e.V., 8 Dec 2024

Essential requirements for DPP Service Providers from a Machinery and Equipment Manufacturer persepctive: 1. Data security and integrity: DPP service providers must adhere to strict data security standards to protect sensitive product information. This includes in particular; the use of the…

Consultation response

Fertilizers Europe, 10 Dec 2024

Please find enclosed Fertilizers Europe's feedback regarding the call for evidence for the Digital Product Passport rules for service providers.

Consultation response

YARA BELGIUM S.A., 10 Dec 2024

It is essential that DPP Service Providers use standardized formats and protocols to ensure interoperability across different sectors and support operational flexibility. This will facilitate seamless integration and data exchange, reducing the burden on manufacturers to comply with varying…

Consultation response

Manufacture Française des Pneumatiques Michelin, 10 Dec 2024

Michelin welcomes the call for evidence on a delegated act laying down rules on the operation of DPP service providers within the digital product passport. Indeed, Michelin, as a tyre manufacturer, will issue Digital Product Passports for the tyres it markets in Europe and will need to entrust…

Consultation response

Plastics Europe, 9 Dec 2024

Plastics Europe considers the Digital Product Passport (DPP) as a valuable tool for improving the understanding of a products sustainability aspects by its users, increasing transparency among all the actors in the value chain and encouraging innovation in sustainable solutions. The role of service…

Consultation response

European Tyre & Rubber Manufacturers' Association, 10 Dec 2024

The European Tyre and Rubber Manufacturers' Association (ETRMA) welcomes this call on DPP - service providers (DPP SP) requirements. Tyre manufacturers will issue DPPs for the tyres they place on the European market. As such, they will have to entrust the copies of the issued DPPs to a DPP service…

Consultation response

Merck, 9 Dec 2024

Merck Life Science response to EU public consultation on Digital Product Passports rules for service providers public consultation: Merck Life Science would like to provide feedback on several key requirements that are essential for the successful implementation of Digital Product Passports (DPP).…

Consultation response

European Recycling Industries' Confederation, 10 Dec 2024

The European Recycling Industries Confederation (EuRIC) welcomes the opportunity to give feedback on the future delegated act laying down rules on the operation of the Digital Product Passport (DPP) and the role of service providers. Overall, EuRIC considers the DPP as a good opportunity for…

Consultation response

Plastics Recyclers Europe, 9 Dec 2024

Plastics Recyclers Europe (PRE), the organization representing European plastics recyclers, supports the Digital Product Passport (DPP) as a critical tool to enhance transparency in product sustainability under the ESPR. However, to ensure that plastics circularity can effectively benefit from the…

Consultation response

Kaupan liitto ry - Finnish Commerce Federation, 9 Dec 2024

Products sold outside the EU must have a digital product passport to prevent the emergence of dual markets. To ensure the competitiveness of businesses operating within the European Union, the EU must begin to strongly monitor cross-border e-commerce with a new EU-level instrument that supports the…

Consultation response

ZVEI e.V. - Verband der Elektro- und Digitalindustrie, 10 Dec 2024

Please find attached the feedback of ZVEI - German Electro and Digital Industry Association on the Call for Evidence on DPP Service Providers.

Consultation response

H M Hennes Mauritz AB, 10 Dec 2024

H&M Group would like to thank the Commission for the opportunity to answer the consultation on the DPP service providers. Since service providers will be storing the large amounts of data about our products, we consider it important to provide comments on the security-, financial-, and…

Consultation response

RTE Réseau de transport d'électricité, 10 Dec 2024

Please, find attached RTE's feedback on the call for evidence on the Digital Product Passport (DPP).

Consultation response

FEAD, 10 Dec 2024

FEAD, the European Waste Management Association, welcomes the European Commission's proposal for the Digital Product Passport (DPP) under the Ecodesign for Sustainable Products Regulation. As representatives of the waste management private sector, we recognise the DPP as a key tool to promote…

Consultation response

European Express Association, 9 Dec 2024

The European Express Association (EEA) is pleased to provide its feedback to the consultation regarding the "Digital product passport rules for service providers" in its attached letter. The EEA is available to address any questions or requests for clarification via our Secretariats functional…

Consultation response

CLECAT - European association for forwarding, transport, logistic and Customs services, 9 Dec 2024

CLECAT, the European Association for Forwarding, Transport, Logistics, and Customs Services, welcomes the European Commissions initiative on the Digital Product Passport (DPP). We emphasise the need for ongoing trade involvement to ensure the DPP enhances transparency and sustainability without…

Consultation response

TIC Council, 10 Dec 2024

TIC Council welcomes the opening of the discussions on the implementation of the DPP. An ex-ante certification scheme is the most likely to result in the success of the DPP initiative. Enforcement levels are likely to be low, especially in the first few months of legislation implementation, leading…

Consultation response

Decathlon SE, 10 Dec 2024

Decathlon welcomes the intention of the Commission to adopt a delegated act laying down rules on the operation of DPP service providers. We are looking forward to participating in the future consultations and discussions and stand ready to share our experience on the topic. For more details, please…

Consultation response

Association of the European Heating Industry, 9 Dec 2024

The association of the European Heating Industry (EHI) would like to stress the need for the Commission to take into account the activities on the building information modelling (BIM) for the development of the Digital Product Passport. More concretely, the standardized BIM data should be…

Consultation response

Japan Business Council in Europe, 10 Dec 2024

The Japan Business Council in Europe (JBCE) and Japanese 4EE industrial associations (JP4EE: JEMA, JEITA, JBMIA, CIAJ) support the idea that proving and transparently demonstrating the sustainability of an entire product lifecycle using a Digital Product Passport (DPP) would benefit both consumers…

Consultation response

Metal Packaging Europe External Affairs ASBL, 10 Dec 2024

Metal Packaging Europe (MPE) welcomes the COMs focus on increasing the sharing of information and transparency along the supply chain with the help of digital product passports (DPP). However, there are concerns, on the scope, granularity and accessibility of the information requested for the DPP.…

Consultation response

TÜV-Verband e. V., 10 Dec 2024

The TÜV Association welcomes the opportunity to provide feedback on the ESPR delegated act as regards DPP service providers. Given their crucial role in storing and processing DPP data on behalf of responsible economic operators, robust requirements must be established to ensure a high level of…

Consultation response

European Garage Equipment Association, 10 Dec 2024

EGEA welcomes the opportunity to give feedback on the Commissions call for evidence in the context of the Ecodesign for Sustainable Products Regulation, the digital product passport (DPP) and the planned delegated act adoption laying down rules on the operation of DPP. EGEA is the European Garage…

Consultation response

VinylPlus, 9 Dec 2024

VinylPlus, the voluntary commitment of the European PVC industry to sustainable development, supports the implementation of the Digital Product Passport (DPP) as a tool for enhancing transparency and circularity. To ensure its success, the governance and operation of DPP service providers must…

Consultation response

Avery Dennison Materials Europe BV, 10 Dec 2024

Avery Dennison wishes to share its perspective on the forthcoming Delegated Act on Digital Product Passport (DPP) service providers in the context of the implementation of the Ecodesign for Sustainable Products Regulation (ESPR). As an associate member of the CIRPASS consortium, Avery Dennison has…

Consultation response

Small Business Standards, 10 Dec 2024

Small Business Standards (SBS), the European association representing SMEs in standardisation, welcomes the opportunity to contribute to the development of rules for Digital Product Passport (DPP) service providers. The Ecodesign for Sustainable Products Regulation and the DPP will foster…

Consultation response

European Advanced Carbon and Graphite Materials Association, 10 Dec 2024

Service providers will be subjected to intense competition and will have to answer the requests of demanding customers. They will have to ensure a very high level of security for confidential business data. They will need to guarantee swift and transparent interoperability with their competitors.…

Consultation response

Hazardous Waste Europe, 10 Dec 2024

Please find enclosed Hazardous Waste Europe (HWE) feedback to the call for evidence on DPP - rules for service providers.

Consultation response

Association of Issuing Bodies, 10 Dec 2024

Our understanding is that digital product passports (DPP) aim to make information such as product carbon footprints (PCF) more accessible and reliable. Energy disclosure is the interface between tracking emissions in the energy sector with guarantees of origin (GO) and sustainability reporting…

Consultation response

OsloMet – Oslo Metropolitan University, 10 Dec 2024

The data the service providers will handle depends on the content of the Digital Product Passport (DPP) This will be different for the various product groups that the DPP will apply to. It is therefore important that service providers can accommodate different configurations. It is further…

Consultation response

COSMED, 10 Dec 2024

Please find enclosed the contribution of Cosmed, the cosmetic association for SMEs.

Consultation response

Suomen Tekstiili ja Muoti ry, 10 Dec 2024

Finnish Textile & Fashion (STJM) thanks for the opportunity to comment on the call for evidence focused on the Digital product passport (DPP)- rules for service providers. STJM is an interest organisation for the Finnish textile and fashion industry, whose member companies produce clothing,…

Consultation response

Fédération des Industries Electriques, Electroniques et de Communication, 9 Dec 2024

Assessment on Costs and Benefits We are not convinced that third party service providers are essential for the functioning of a DPP system as they raise additional costs, and economic operators can also ensure persistent DPPs even in case of liquidation, insolvency or cessation of activity. The…

Consultation response

BSH Hausgeräte GmbH, 10 Dec 2024

BSH views on the intention of the EU Commission to adopt a delegated act laying down rules on the operation of DPP service providers BSH actively supports regulations that encourage innovation, sustainability, and fair competition. We recognise the potential of the Digital Product Passport (DPP) to…

Consultation response

REUP Technologies Holding BV, 10 Dec 2024

We appreciate the opportunity to contribute our insights on implementing the Digital Product Passport (DPP). As RE&UP Technologies, a Dutch-headquartered textile waste recycler with facilities in Türkiye, we are directly involved in fostering circularity within the textile industry and enabling…

Consultation response

U.Di.Con. APS Unione per la Difesa dei Consumatori, 9 Dec 2024

Come U.Di.Con. APS, accogliamo con favore la proposta della Commissione Europea relativa al "Passaporto Digitale di Prodotto" (DPP). Riteniamo che questo strumento sia essenziale per garantire maggiore trasparenza, sostenibilità e tracciabilità lungo le filiere produttive, offrendo ai consumatori…

Consultation response

Namirial S.p.A., 5 Dec 2024

The European Sustainability Reporting Regulation (ESPR) introduces a new paradigm for product sustainability, focusing on a life-cycle approach. From a cybersecurity perspective, ensuring the security of systems managing Digital Product Passports (DPPs) is crucial. These systems should be designed…

Consultation response

Industrieverband Schneid- und Haushaltwaren, 4 Dec 2024

The Industrieverband Schneid- und Haushaltwaren e.V. (IVSH) in general welcomes the Commission's initiative to implement the Digital Product Passport (DPP) as part of the new EcoDesign Regulation - if designed and executed well. As the representative body of our industry, we recognize the positive…

Consultation response

GS1 in Europe, 10 Dec 2024

Please see attachment for GS1 in Europe's feedback to the call for evidence on the rules for DPP service providers. Thank you.

Consultation response

Adolf Würth GmbH Co. KG, 10 Dec 2024

Beitrag zur Konsultation über die Festlegung von Vorschriften für DPP-Service Provider Wir bedanken uns für die Möglichkeit einer Rückmeldung. Die Würth-Gruppe begrüßt generell die Implementierung von Digitalen Produktpässen in hohem Maße und sieht darin ein wichtiges Werkzeug, um die Lebenszyklen…

Consultation response

Sika AG, 10 Dec 2024

Dear Members of the European Commission, Sika fully supports the goals of Ecodesign for Sustainable Products Regulation and Construction Products Regulation and we are eager to actively contribute and enable the transformation towards a Circular Economy in the European Union. Please find attached…

Consultation response

Arianee Project, 10 Dec 2024

Please find attached the Arianee Project association contribution for the Call for evidence Digital product passports rules for services providers

Consultation response

Kezzler, 10 Dec 2024

Kezzler is a potential DPP Service Provider and are at current helping to prepare our customers IT architecture to comply with ESPR and its upcoming Digital Product Passport. Kezzler is leading a lighthouse pilot in CIRPASS-2, has seconded experts to CEN/CENELEC JTC 24, and is a member of the…

Consultation response

Aura blockchain consortium, 10 Dec 2024

The Aura Blockchain Consortium (Aura) welcomes the opportunity to comment on the Commissions Call for Evidence. Companies face uncertainty due to the nascent nature of the Digital Product Passport (DPP) service providers market, marked by a diversity of actors varying in (i) structural and…

Consultation response

Der Verband für Medien- und Veranstaltungstechnik, 10 Dec 2024

The German Entertainment Technology Association (VPLT) would like to thank the Commission for the opportunity to give feedback on the rules for DPP service providers storing DPP data for economic operators and/or mandatory backup copies. VPLT represents the interests of different economic players…

Consultation response

European Electronics Recyclers Association, 10 Dec 2024

Initial Observations on the European Commissions Digital Product Passport (DPP) Proposal Joint Submission by EBRA and EERA December 2024 As representatives of the European waste management sector, for electronics and batteries, EBRA and EERA welcome the opportunity to provide initial observations…

Consultation response

Fairly Made, 9 Dec 2024

Fairly Made is a mission-driven company with five years of experience helping fashion brands improve their social and environmental impact. We provide a SaaS platform to support CSR challenges and compliance with environmental legislation. Our three-pillar tool includes: 1. Traceability:In-depth…

Consultation response

U.S. Cotton Trust Protocol, 9 Dec 2024

In order for the Digital Product Passports (DPPs) to be a credible source of information, it is important that they privilege the best possible data available. When recent direct data is available, this should be made clear to the audience and preferred to database information. We would therefore…

Consultation response

Better Cotton Initiative, 9 Dec 2024

Implementation of the Digital Product Passport on clothing presents an unparalleled opportunity to meaningfully measure and report the environmental footprint of textiles. DPP-derived data from waste collection facilities could report the average lifespan of clothing made by brands and this…

Consultation response

figawa, 6 Dec 2024

Dear Ladies and Gentlemen, In general, the development of a standardized framework for digital product passport service providers is to be welcomed. It seems essential that a standardized EU-wide database is used and that several databases are not created. It is also important to regulate a…

Consultation response

yellow3 ApS, 28 Nov 2024

Feedback on the Proposed Framework for Digital Product Passport Service Providers Alignment with Yellow3's Vision Yellow3 welcomes the European Commission's initiative to establish a standardized framework for Digital Product Passport (DPP) service providers. As a technology company committed to…

Consultation response

icecat N.V., 27 Nov 2024

SUMMARY: GRANULAR INFORMATION RIGHTS MANAGEMENT WILL BE THE ACHILLES HEEL OF THE DPP. USE AN AGILE APPROACH FOR DPP AND START WITH AN MVP BASED ON OPEN CONTENT. The recommendation for the development of Digital Product Passport is to use an Agile approach. Start with the Minimum Viable Product with…