icecat N.V.
icecat
Icecat is operating the leading data pool in EU for e-commerce and product information.
ID: 402819394649-43
Lobbying Activity
Response to Digital Product Passport (DPP) service providers
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 the easiest use case for a DPP. Make this a success and learn. This will keep cost for EU business down and create adoption. Expand in a period of multiple years to the more difficult use cases. This will prevent overengineering solutions which bring an enormous cost burden. Currently the digital product passport is being over-engineered to the most difficult use case as described below. MOST DIFFICULT DPP USE CASE: GRANULAR DIGITAL RIGHTS MANAGEMENT ON SENSITIVE INFORMATION An Economic Operator Creates a DPP with Competitor sensitive information on Item level based on Configure to Order. A downstream value chain actor wants to Read and Update a DPP on Item level via an API linked with its ERP system using this Competitor sensitive information. This use case uncovers the DPP Achilles Heel which is creating verifiable N-M Trust relations on sensitive information. THE PROBLEM IS THE N-M TRUST RELATION An Economic Operator needs to keep control of who is able to access the Competitor Sensitive information. In the end all Economic Operators will want to control this information with all their value chain actors, resulting in an N-M relation, all to do about trust and digital identities. STANDARDIZED WIDE SPREAD AUTHENTICATION IS DIFFICULT AND FOR M2M API COMMUNICATION EVEN MORE SO. A solution can be the use of eIDAS for authenticating a Value Chain Operator. The drawback is that there is no widespread implementation of eIDAS, for every employee the cost would be euro 30-40 per year and M2M communication is not yet implemented in the ERP system. ECONOMIC OPERATORS NEED TO CONTROL THEIR SENSITIVE INFORMATION LEADING TO AN ADMINISTRATIVE OVERHEAD Even with eIDAS the Economic Operator would need to authorize the Value Chain Operator in some way to access their crucial competitor sensitive information. This is the most complex part of the puzzle. The fear of losing control on the flow of information is, in our humble opinion, so large that the Economic Operator wants to keep total control either in their own administration and maybe at a DDPaaS provider. This will lead to complex administrations, finicky onboarding and day to day management of the authorizations and an administrative overhead other geopolitical economic region do not have. POINT OF VIEW: THE MOST DIFFICULT USE CASE IS FOR A LIMITED NUMBER (~5%) OF ECONOMICAL VIABLE ACTIVITIES BUT WILL BE ~80% OF THE COST. In all the DPP pilots there is a lot of wishful thinking on activities which might take place like refurbishing and repair of furniture but in the end there is only a limited amount of economically viable business activities. The first indication is that the DPP will not change the way of working dramatically for these businesses. Only in the remarketing of refurb products the DPP will play a role. The administrative overhead of this most complex use case will have an impact on personnel and IT. My assumption is that this would then be 80% of the cost of the DPP for any company. With the current scarcity to find good personnel, large companies will outsource to other geopolitical regions and SMEs will suffer. RECOMMENDATION: KEEP IT SIMPLE START WITH A MINIMAL VIABLE DPP FOR 20% OF THE COST WITH 80% OF THE EFFECT Therefore, the recommendation is to keep the initial DPP simple. Start with the easiest use case at 20% of the cost of the complex one. Start with information which is readily available and will give immediately 80% of the benefits in market awareness. MVP: DPP WITH OPEN CONTENT INFORMATION An Economic Operator Creates a Digital Product Passport with Public Information on Model level accessible as Read-Only via the Web to the General Public
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