Aura blockchain consortium
AURA
The purpose of the Association is to promote socially responsible, sustainable, and customer-centric business practices throughout the lifecycle of luxury products by leveraging blockchain and other current and/or future technologies notably in relation to (i) the tracking and tracing of raw materials, parts and components, as well as finished products, (ii) proof of origin, authenticity and/or ownership, (iii) transparent manufacturing and service processes, and/or (iv) the creation and commercialisation of digital objects.
ID: 034467693444-45
Lobbying Activity
Response to Digital Product Passport (DPP) service providers
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 operational characteristics (size, technological capabilities, information security) and (ii) organizational nature. Brands face the challenge of ensuring that DPP services not only comply with the legal framework but that such services also provide the trust and security necessary for their customers and stakeholders. - Without a clear framework to ensure viable and secure solutions for DPP service providers, companies risk facing administrative and/or financial burden. - Without a technology-neutral framework to achieve a level-playing field, DPP service providers which rely on the blockchain may be put at a disadvantage. - Without a proportionate regulatory, innovative DPP services providers may be prevented from accessing the market. Therefore, fair, proportionate and technology-neutral requirements must be developed for all DPP service providers. 1) Ensuring the financial viability of the DPP service providers. Companies may be exposed to service disruptions in case of insolvency or financial instability of the DPP service provider. Companies may be unable to fulfill their sustainable commitments due to their dependance on the continued availability of accurate data on recycling/reuse. Financial viability requirements are necessary to prevent the risks of sudden failure and to ensure that DPP data remains accessible. DPP service providers should thus be required to secure appropriate financial backing for medium/long-term stability. 2) Ensuring information security. Companies rely on DPP service providers to secure all sensitive data about their products, including personal, product and commercial information. Blockchain, although recognized as one of the most secure solutions for data privacy/immutability, is not universally adopted by DPP service providers. The latter may operate different underlying technologies- with lower quality/security/transparency compared to the blockchain. This of relevance for the security/reliability of the DPP data which are crucial for customers/stakeholders, who expect their personal and product information to be handled with the highest levels of security. To deliver the trust they require (which is vital to the adoption of DPPs), the new framework should mandate that all providers meet established security standards, so that product data is protected from unauthorized access. The regulatory framework must address data ownership/access/use, so that data sovereignty is maintained (where relevant with backup principles requiring a copy of the DPP to be maintained within the EU). Aura supports compliance with EU regulations; the requirements under the future Delegated Act should be consistent with applicable EU data regulations. Thus, brands will benefit from (i) long-term access to product data to manage product life cycles, improve recycling rates and enhance traceability, (ii) reduction of financial and operational risks. Last, a certification of providers could be envisaged but should not place a disproportionate burden on companies that would like to operate in this space. The regulatory framework should give proper recognition to the more secure and reliable technologies such as the blockchain (which inherent features already ensure trust, security and data integrity). Aura welcomes the drive for harmonization of the rules for DPP service providers, based on the principles of economic viability, data security, interoperability and technological neutrality. Aura agrees with the approach taken by the Commission thus far, all while calling for a more explicit recognition of the specific contribution of the blockchain to the DPP which must be a key part of the forthcoming impact assessment phase.
Read full response