EuroCommerce Position on the DPP under the European Product Act

EXECUTIVE SUMMARY
EuroCommerce welcomes the upcoming European Product Act (EPA) and definition therein of a horizontal framework for rules concerning Digital Product Passports (DPPs). We support the upcoming reforms’ potential to strengthen digitalisation, circularity, and product compliance, and help address the challenge of non-compliant product shipments from third countries. Simultaneously, we stress that DPP implementation must be gradual, and guided by the principles of proportionality, practicality and legal certainty.

We caution against the DPP evolving into a documentation repository system, instead of a product information tool. Information requirements should be limited to what is necessary under relevant product legislation, avoiding excessive data collection, item or batch level serialisation by default, thirdparty verifications and the inclusion of sensitive technical files, which would create significant costs, cybersecurity risks and administrative burdens, particularly for SMEs, without additional benefits for product compliance.

At the same time, we see value in allowing businesses to use the DPP as a single access point for a broader range of product-related information, beyond what is strictly required under product legislation. Enabling such flexibility would help companies maximise the benefits of their investments in DPP systems and further reduce fragmentation of product information across multiple channels.

We advocate for a phased DPP introduction with sufficiently long transition periods, clear technical standards, data requirements and operational infrastructure in place before obligations apply. We also call for proportionate allocation of responsibilities across the supply chain, ensuring distributors are not held responsible for the accuracy of DPP data and circular-economy operators are subject to realistic and role-appropriate obligations. Finally, we call for a digital-first approach to product information, except for essential/safety information which should remain with the physical product, while this term could benefit from a definition. Lastly, we emphasize the need for coherence across EU legislation and further guidance potentially under the Blue Guide.

Read the full text of the Position paper below.