Digital Product Passport (DPP) service providers

As an experienced service provider with traceability projects with customers across 10 different industries dating back to 2016, Circularise is delighted to share its lessons learned from running DPP services and important insights shared from customers about their day-to-day experience with using our services.

At Wsh-lst, we focus on maximising the utility and usability of Digital Product Passports (DPP) for end consumers. By leveraging the data within DPPs, we aim to enhance product authentication, labeling, and traceability, fostering more robust second-hand markets and extending product lifecycles. 1. Open Design: We believe it is critical for the DPP system to be designed with openness and interoperability in mind.

Contribution to the consultation on the establishment of rules for DPP Service Providers We thank us for the opportunity to provide feedback. The Würth Group broadly welcomes the implementation of digital product passports and sees it as an important tool to prolong the life cycles of products and reduce their environmental impact.

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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).

Circuland, a UK-based company specialising in construction products and building passports, advocates for the development of Digital Product Passports (DPP) as outlined in the Ecodesign for Sustainable Products Regulation.

Product DNA is delighted with the opportunity to share insights on implementing the Digital Product Passport (DPP) as we closely follow the regulations and directives under the European Green Deal. Mapping supply chains at a batch level is a core part of Product DNAs expertise, which enables companies to manage supply chain compliancewhether for due diligence or reporting.

OpSec is an established provider of downstream traceability, specializing in solving authentication, commercial compliance, and engagement problems through digital platforms and secure on-product devices - at scale. As such, OpSec is well placed to comment on requirements for DPP service providers.

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.

PDT Norway would like to thank the European Commision for the opportunity to provide feed back for rules for DPP service providers. PDT Norway is an industry initiative on providing and managing industry level data templates for the Norwegian architecture, engineering, construction and operations (AECO) industry.

Laava is a provider of secure DPPs and connected product solutions. We leverage our technology for traceability and authentication to serve customers globally. We fully endorse the creation of a delegated act to provide greater clarity on DPPSP requirementswhether this refers to a third party vendor or an internal service bureau.

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 assurance-related requirements.

Ladies and Gentlemen, I am taking part in this consultation in my honorary role as President of the ASA Federal Association (www.asa-verband.de, ) and board member of the EGEA Association (www.egea-association.eu) based in Brussels. Both associations are listed in the respective lobby registers. (ASA R000718) (EGEA 42705074342-04) The associations represent the interests of the workshop equipment industry.

SGS welcomes the opportunity to comment on the call for feedback on Digital Product Passport (DPP) service providers related to the ESPR. Clear requirements should be set out to ensure a consistent approach for the delivery of the DPP. We support the introduction of a certification scheme with conformity assessment bodies (CAB) involved and delivered by Notified Bodies.

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.

We understand the objective is to set up a reliable and secure DPP system for all its users and to ensure a level playing field for responsible economic operators that must create a DPP, register it and store the mandatory backup copy. Further that the commission are considering the design of a system to provide assurance for businesses that DPP service providers comply with the requirements.

We understand the objective is to set up a reliable and secure DPP system for all its users and to ensure a level playing field for responsible economic operators that must create a DPP, register it and store the mandatory backup copy. Further that the commission are considering the design of a system to provide assurance for businesses that DPP service providers comply with the requirements.

The EU/UN Digital Product Passport Common Rules and Common Quality Data Dictionaries for all Quality Passport Service Prodivers Mein Name is Michael Hofmann. I am the founder and managing director of CDMM GmbH – common data management from Jena | Thüringen | Germany. CDMM GmbH has been a product data, technology, platform and service provider of the IAM Independent Afterservice Market since the mid-2000s.

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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. And finally they will not be able to monetise the wealth of high-value data that they will be handling.

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 requirements while ensuring compliance.

Circulor is the market leader in materials traceability and battery passports. We welcome the opportunity to comment on the rules for DPP service providers, drawing on 8 years of experience working with major manufacturers and their entire supply chains, back to extraction or scrap.

​​Adan supports the key objectives of the Digital Product Passport, particularly enhancing the sustainability of products, and contributing to the European economys green and digital transition. Transparency is key for consumers wanting eco-responsible products and, in this area, an undeniable challenge is greenwashing.

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 improve product sustainability but stress the need for smart implementation.

The implementation of Digital Product Passports (DPPs) in the European Union is a core element of the EUs broader sustainability and circular economy initiatives, such as the proposed Eco-design for Sustainable Products Regulation and measures under the European Green Deal.

This comment represents MyLime's response to the European Union's questions regarding the implementation of Digital Product Passports (DPP). As a provider of Digital Product Passport our experience since 2018 has allowed us to develop a product that meets the market demands, creating a repository of information collected from various stakeholders, such as the brand, the end consumer, and partners (suppliers…

ACEA welcomes the initiative of the European Commission to gather evidence in view of drafting the rules applicable to DPP service providers, and would like to share some concerns and questions which we hope will be addressed in the delegated act - please see attachment.

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 information and improve value chain communication.

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 strategy to support customers in their green transformation.

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 administrative burdens for all actors, and guarantees the safety and integrity of the DPP system.

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 to low DPP uptake, or an abundance of DPP systems that are data venerable.

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 sustainable material cycles.

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.

Dear Members of the Commission, We sincerely appreciate your dedicated efforts to enhance and strengthen our European community. On behalf of the Norwegian Building Authority, I am pleased to submit our input in response to the call for evidence on Digital Service Providers. Thank you for considering our contribution. Kind regards, [name removed] director

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.

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 provider.

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 national cluster for the fashion and textile industry in Norway (NF&TA).

Clarity regarding environmental impacts Many of our member companies want to move forward with the DPP but are hesitant because of the lack of clarity regarding mainly methodologies, but also which impact categories will be in the DPP by when.

- 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 to warrant harmonized implementation in the Internal Market.

As part of the harmonisation of the rules for the provision of services related to the digital product passport, we consider it appropriate to lay down the following: The economic operator (manufacturer) should have only one service provider as a partner for the entire EU economic market. I.e.

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S1Seven has developed Digital Material Passport, a platform for exchanging material data across chemicals, metals, and wood industries. Our recommendations stem from extensive experience in the steel industry, which encompasses approximately 500 manufacturers, 3,000 distributors, and 500,000 EU companies that create steel products: 1.

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, accessories, interior textiles, technical textiles and non-woven fabrics, among other things.

The International Cotton Advisory Committee (ICAC) welcomes the opportunity to contribute to the European Commissions Call for Digital Product Passport (DPP) initiative under the Ecodesign for Sustainable Products Regulation (ESPR). ICAC is an association of governments from cotton producing, consuming, and trading countries, including the European Union (EU).

Tappr is a provider of Digital Product Passport (DPPs) solutions. We empower brands to build trust and transparency with consumers by showcasing product information, sustainability practices, and brand stories through engaging digital experiences.

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 Product Passport service providers: 1.

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.

TRAWEBA relies on TraWeBa’s cooperation as a publicly funded consortium of the battery value chain established throughout Germany to support companies in their transition. Based on our expertise and intensive exchanges with stakeholders, for example in the context of our online event on battery innovation in the spotlight, we are convinced that the success of the Digital Product Passport specifically of the battery…

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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. Coherent rules must be set up to guarantee the reliability and security of the DPP.

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 advancing recycling and the circular economy.

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 resilience and a level-playing-field for DPP service operators.

Thank you for the opportunity to provide feedback on the call for evidence regarding the impact assessment of the Digital Product Passport (DPP) Rules for Service Providers. As digiGO, the administrator of DSGO, the digital data space for the built environment in the Netherlands, we represent the outcome of extensive collaboration with all stakeholders in the built environment from clients to contractors, service…

Madeby is a UK based data solution for the circular economy, providing a DPP offering currently for the textile and apparel sector. We wholeheartedly welcome the efforts of the Commission to introduce a digital identity for each item entering the market - this level of accountability is required to address the current challenges and support scaling the circular economy.

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 see our written submission.

The Finnish Electrotechnical Trade Association (STK) welcomes the opportunity to contribute in the creation of uniform requirements for digital product passport (DPP) Service providers. The main principle is that the administrative burden on manufacturers should be in proportion with the benefits that are obtained in the value chain, and therefore the information requirements of product passports should be limited…

One could advantageously consider the commercial DPP dataset which meets the customers from an outside-in view, meaning from the customers perspective, to gain confidence in solution. The DPP dataset stands on a series of pillars from different data actors who are all sources of information to the aggregated DPP dataset.

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 and users.

Occtoos Perspective on Digital Product Passport (DPP) Requirements As a provider of digital solutions, Occtoo recognizes the importance of ensuring that Digital Product Passport (DPP) services meet the needs of responsible economic operators.

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 including PCFs.

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 transparency across product value chains, support sustainability objectives and enable the transition to a circular economy.

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 in the event industry such as manufacturers, service providers, operators, dealers, retailers and distributors.

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 regarding the European Commissions proposals for the Digital Product Passport (DPP).

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 copies of these DPPs to a DPP service provider.

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.

Thank you to the European Commission for the opportunity to provide feedback on this matter. The assumption in the call for evidence inquiry states: "This delegated act will set out a framework for DPP services, a new niche digital industry market created by the ESPR." In response to this statement, we want to emphasize that for the DPP to truly achieve the objectives set forth under the Green Deal and ESPR, the DPP…

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 need for a back-up DPP at the DPP creation should be evaluated.

The AI Working Group operating at the Ministry of Digital Affairs, as part of its activities, has analysed the draft regulation on establishing a framework for setting ecodesign requirements for sustainable products, amending Directive (EU) 2020/1828 and Regulation (EU) 2023/1542 and repealing Directive 2009/125/EC.

Implementing the Digital Product Passport (DPP) in clothing offers a unique chance to accurately measure and report the environmental impact of textiles. Data derived from DPPs at waste collection facilities could reveal the average lifespan of clothing from various brands. This evidence-based sustainability measure could then inform the environmental scoring and labeling of current clothing lines.

For SMEs in the construction sector, the obligation to deliver digital product passports will be challenging. Most of them do not have the appropriate IT infrastructure. If this is not organized properly, it will create a lot of overhead costs or will not be implemented correctly. Yet, it is also essential that reliable product data are available in case buildings have to be changed of renovated.

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). We supply scientists with the tools to carry out their work.

PicoNext is a Digital Product Passport service provider, working with organisations in the EU and with organisations selling into the EU across a range of industries. * Technical standards and data format schema The definition of data attributes at present comes from a variety of sources, including the ESPR, future delegated acts, and a variety of related legislation.

The EU's focus on Digital Product Passports is a significant step towards a more sustainable and transparent future. It is indeed crucial that the possible solutions should not create a disproportionate burden, especially on SMEs.

DPPs have the potential to be a cornerstone of the EUs efforts toward a more sustainable and transparent economy. However, we have concerns regarding the proposal to make DPPs fully updatable after issuance. While we recognize that some degree of adaptability may be necessary for certain types of data, allowing unrestricted changes poses significant risks to the reliability and trustworthiness of the DPP system.

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 analysis of supply chains and product journeys. 2.

My name is Jonathan Clark and I am the Managing Agent for the DOI Foundation (https://doi.org), a not-for-profit organisation that governs the Digital Object Identifier (DOI®) system on behalf of the agencies who manage DOI registries and provide services to their respective communities.

The implementation of the Digital Product Passport (DPP) for textiles and clothing presents a unique opportunity to measure and report the environmental and social impacts of the industry. Currently, the sector lacks reliable data on product longevity, making it difficult to track the durability of items.

The standards reflect a consensus among all stakeholders on a very wide range of products; therefore, the content of the standards structured in an appropriate format could support the implementation of the DPP by providing reliable content. Standardisation organisations such as AFNOR, through their digital transformation initiative, integrate this ambition to support industry.

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We are a DPP Solution Provider, and from our point of view, here are some important points to consider: -[Enhanced Functionality and Strategic Value of DPPs]: DPPs should not only serve as compliance tools but also as strategic assets for companies. For instance, DPPs could be leveraged as marketing or communication tools. Providers must not use this data for commercial purposes without explicit consent.

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 DPP, PRE would like to highlight key issues that need to be addressed during the design of the secondary legislation.

Thank you for this opportunity to feedback! Our observations/concerns as SME producing type approved speedpedelecs. 1. Conflict between confidentiality and circularity: Reverse engineering power will only improve over the years.

In principle, we fully recognize the necessity of establishing clear rules for DPP technology service providers，and consider it a critical component for the effective implementation and operation of the entire DPP system. The ESPR proposes that the EU commission will establish a registry interconnected with its single customs window, which will maintain registration records.

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.

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 vital work of national supervisory authorities.

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 inadvertently creating non-tariff barriers to legitimate trade.

Supporting Transparency and Sustainability: We recognize that the DPP aims to enhance product lifecycle transparency by digitally storing and sharing essential product information, such as environmental impact, material composition, and compliance data.

A.I.S.E., the European association for cleaning and maintenance products, welcomes the European Commission's efforts to advance transparency and sustainability through the implementation of the Digital Product Passport (DPP) under the Ecodesign for Sustainable Products Regulation (ESPR).

1. For economic operators responsible for products, if they have their own professional teams and advanced technological capabilities and can convincingly prove that they are capable of hosting the DPP on their own, they should be granted approval to go through the certification process of the certification body.

1: Clear requirements for services User-friendliness, uptime, reliability, and cybersecurity Follow international and national standards and guidelines for data quality, data quality management, availability, and security.

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.

As U.Di.Con. APS, we welcome the European Commission’s proposal for the Digital Product Passport (DPP). We believe that this instrument is essential to ensure greater transparency, sustainability and traceability along production chains, giving consumers the opportunity to make more informed purchasing choices.

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This document represents Norsk Byggtjeneste AS's response to the European Union's questions regarding the implementation of Digital Product Passports (DPP). Established in 1956, Norsk Byggtjeneste is Norway's leading provider of digital solutions and services for the construction industry.

https://www.trick-project.eu/ provides a circular product information management system, based on a data collection platform secured by Blockchain, which will support DPP for textiles. It is one of the first EC funded projects in this domain reaching its conclusions.

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 email: [email removed].

1.Question: As a DPP service provider outside the EU, do we need to backup data in the local database in Europe for data storage? Or is it possible to provide DPP services if the DPP data is stored entirely outside the EU, as long as the solution and company qualifications meet the regulatory requirements? 2.

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.

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

We at Sharecat support the EU Digital Product Passport and see significant potential for improved collaboration and efficiency across parties in supply chains utilising the DPP. However, due to the potential sensitivity of the information being shared via the DPP it is important that the requirements for service providers are based on practical considerations to ensure the credibility and robustness of the DPP.

Creating a standardized Digital Product Passport framework that is practical, accessible, and not prohibitive for small and medium-sized fashion brands is vital. Ensuring that the underlying requirements, processes, and interfaces are simplified and enables SMEs to meet these obligations without undue strain.

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 align with principles of fairness, security, and practicality, particularly for material-intensive industries like PVC.

The "Battery Passport Technical Guidance" indicates that DPP should be built on a decentralized system, suggesting that blockchain or other distributed ledger technologies have the potential to serve as the foundation for DPP implementation. If this is the case, then the DPP system should feature a decentralized, cross-border or regional database or file system.

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 evidence-based measure of sustainability could then determine the environmental score and labelling of clothing currently being…

As a DPP Solution Provider, we see great opportunities in the DPP initiative, but would like to highlight some important points: Technology neutrality: The requirements should be formulated in a technology-neutral manner so as not to disadvantage innovative solutions such as DLT. Acceptance of DLT as modern storage solutions: Blockchain and DLT storage solutions should not only be supported, but actively promoted.

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

The DPP is an unparalleled opportunity to meaningfully measure and report the environmental footprint of textiles. DPP-derived data from waste collection facilities also could report the average lifespan of clothing made by brands and this evidence-based measure of sustainability could help determine the environmental score of clothing currently being made by those brands.

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 harmonised standards being currently created for the DPP system. 2.

To whom it may concern, We are 3E, a leading service provider specializing in regulatory compliance, data management, and sustainability solutions. We deliver innovative solutions for collecting and transferring information across the value chain, including Digital Product Passports (DPPs).

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 possible framework for the operating costs / cost framework of the DPP service provider.

Unfortunately, it is not yet free from ESPR. The legitimate concern of the Austrian trade in building materials and iron is justified by the existential need for information on the part of economic operators, from the point of view of trade, distributors and distributors within the meaning of the ESPR. The new Ecodesign Regulation has prioritised 12 product groups in accordance with Article 18 of the Regulation.

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Feedback on the Digital Product Passport Rules for Service Providers We welcome this initiative, which is essential for achieving sustainability and traceability objectives. Below are our key observations and suggestions: 1. Standardization - Consistent rules and standards across all product types and Member States are crucial. This will simplify processes for manufacturers, recyclers, repairers, and even consumers.

1. I believe there is positive potential here to create a common way of operating which could increase adoption of DPP. 2. I think the inclusion of financial viability in the rules is a mistake that will only keep startups out of the market to the benefit of bigger companies and established providers without accomplishing the intended goals.

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

I believe that the DPP can improve the recycling and the progress of circular economy. After our team's study and demonstration for two years supported by government and our industry, we found 4 tasks that should be incorporated in the standard for service provider. 1.

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 with a "defense in depth" strategy, taking into account potential attempts to circumvent the regulation.

The DPP provides opportunities to move towards a circular economy, however, we do see some worrying developments concerning the practical implementation. Our worries revolve around three main topics, which we elaborate on below: 1.

We understand and support the desire for more sustainable products, a consideration of the life cycle and the desire for a deeper understanding of the possible environmental impacts that these products can have. However, there must be limits to the desire for more transparency! It is not acceptable if confidential performance and/or material data must be disclosed through the DPP.

The Digital Product Passport (DPP) represents a significant opportunity to promote a circular economy. The term 'DPP service provider' suggests these entities will manage all data points for a single passport. In practice, several software companies will probably be able to provide a certain proportion of the required data.

ABB Electrification welcomes the opportunity to provide input to the upcoming delegated act setting out requirements DPP service providers. Here are our initial main aspects: - Contractual freedom must be the basis of the B2B relation between the economic operator responsible for the DPP and the DPP service provider. The use of third-party services is a free choice of the responsible economic operator.

We are ECHO PRM GmbH, and for the past four years, we have been providing solutions to facilitate interaction and communication between manufacturers and end-users of physical products. Our primary objective is to establish ourselves as a Digital Product Passport (DPP) service provider, with a particular focus on supporting small and medium-sized enterprises (SMEs).

Hi, I would suggest clarifying how exactly the implementation of DPP will be monitored by national / EU bodies. Ex. Who will do what / in which way / at which frequency / financed by whom / what's the penalty, etc. As we learned from previous practices, regulatory requirements will make sense only if a robust monitoring system will be put in place and will be properly financed. Thanks in advance

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.

The lighting industry is already subject to SLR and ELR regulation, with light sources to be registered in EPREL. Would it also be necessary to have a DPP for the containing product? This is already complicated as this lighting industry includes many SMEs/VSEs, unlike other energy-intensive EEA industries for IT or household appliances, which are more often large groups, do not have the means to have resources…

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Coordination is lacking. several initiatives are putting forwarde ideas and suggestions for rules and requirements. Not only the ESPR is governing this issue the CPR also is setting requirements. we need one set of clear and umambigous rules on DPP data providers. The implementation of these rules need to be surveilled to ensure smooth introduction.

Plans for the certification/rules for DPP service providers should be clear, concise and available to follow as soon as possible to allow service providers ample time to comply. In regards to the ECs possible requirement for DPP service providers that relates to the financial viability of the DPP service providers to guarantee long-term access to DPP information.

As an innovator in digital solutions for the construction industry, Cobuilder AS actively supports the development of Digital Product Passports (DPP) frameworks and establishing harmonized approaches to DPP implementation, focusing on standardization and scalability across industries.

Thank you for the opportunity to provide feedback: We have developed a software (SaaS) and started to uniquely identify B2C and B2B objects using RFID, NFC and 2D Code. On the basis of this ID, a clear and unique source of information is made visible and accessible to the end user on the internet in the Content Management System. We call this solution IDConnect.

Filed in German · English published by the European Commission

The digital product passport is a great opportunity for the textile industry to simplify processes and ensure sustainability in the future. It is important for the DPP that information exchange and structure of information be clearly regulated in the DPP so that interfaces of all kinds can be implemented using the same scheme. It is important that service providers have to follow a standard on the DPP.

Filed in German · English published by the European Commission

If the DPP and its associated system can be based on the Asset Administration Shell (AAS) (IEC 63278-1), AAS repositories, and the REST API interfaces for AAS, this would result in significant cost savings, as these technologies are already implemented or currently being implemented in many companies. The AAS technology is already a mature and robust framework that provides a solid foundation for the DPP.

The Digital Product Passport can be a great opportunity for more sustainability and, above all, more transparency along the life cycle of products. Service providers wishing to offer digital product passports need clear guidance on the following issues: What data should be collected on the digital produkpass? Material data, socio-economic data, environmental data, ingredients, etc...

Filed in German · English published by the European Commission

Dear Sir or Madam, I would like to point out that the service of being able to offer a DPP is also interesting for start-ups. Especially in the construction sector with many small, locally based product manufacturers, it should also be possible for new, small software companies to offer this service.

It is important for industry not to have to build a new system here. If the DPP and the DPP system can be built on the basis of the AAS (IEC 63278-1), AAS repositories and REST API interfaces to AAS, this saves enormous costs as these technologies have already been implemented or are being implemented in many companies. The following platform can be used as an example: https://dt.r-stahl.com/

Filed in German · English published by the European Commission

Efforts should be made to limit DPP requirements. Paragraph (e) of Annex III to Regulation 2024/1781 requires that the technical documentation is also accessible to the public. However, these documents may also include in-house know-how, which should not be available to the public (only at the request of the authorities). Unless we want our products to be repaired without difficulty!

Filed in German · English published by the European Commission

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.

Based on preliminary research, there seems to be a conflict between the legislations of circular economy, DPP and trade secrecy, anti competitive behaviour laws. Which of these regulations would take priority in case of a clash is not yet clear. This needs to come from the Commission.

Should the 'Made in Country' initially for textiles, be more clearly defined for consumers on Digital Product Passports? What does 'Made in Country' really mean? For textiles, numerous processes: spinning, dyeing can be conducted in different countries. Does 'Made in Country' therefore only mean the location of the cut'n sew production facility? Why do fashion brands choose to manufacture in particular countries?

We sincerely appreciate the opportunity to contribute our insights on the implementation of the Digital Product Passport (DPP). As a representative of the ASUS Commercial Computers Business Unit, I am directly involved in the ongoing efforts to integrate the DPP framework into our operations. Below, I outline the key challenges and questions we have encountered during the planning and implementation phases: 1.

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.

Dear Madam, Sir, At Orobo, we are excited to provide our feedback to the Call for Evidence - Digital product passport rules for service providers and thereby contribute to the development of the Digital Product Passport (DPP) framework under the Ecodesign for Sustainable Products Regulation.

DPP for electronics would be a great added value! We could finally track the value chain of electronics, and understand the steps it goes through from manufacturing side to customer. It will help with better accounting for carbon footprint (finally we could assess EF for each country i.e.

Hello, Please our feedback here below : 1/ Intellectual Property to be taken into account for products in a competitive environment (Hardware & Software) 2/ Data access to be secured (taking into account previous IP subject) with possibility to re-access to our declared datas 3/ Data encryption to be planned 4/ Infrastructures fiability & performance (eg Reception Acknowledgment to be sent in real time) 5/ Huge data…

Cirpass solution has considered GS1 Link as the ideal solution for HTTP-Based Access architecture. Indeed, considered that as part of the regulation without providing alternatives is representing a market monopoly, which a regulation should not allow.

We have concerns over the platform(s) to support DPP if they are not centrally managed by a suitable neutral organisation (e.g. CEN/CENELEC or similar). There will also need to be significant support for SME businesses which the transition will provide burdensome and challenging with limited resources and expertise in electronic data management. In general the aims are laudable.

Digital Product Passport will be super useful to tackle all the challenges we have been facing over the years. e.g., often our product packaging do not have enough space to affix multiple approval logos, to paste their minimum legal information and above all the entire approval logos and its information update process manually takes forever.

The Digital Product Passport (DPP) represents a radical transformation in production, logistics, and regulatory processes. To ensure a successful transition and minimize risks associated with such a complex shift, it would be essential to adopt a gradual and structured approach that allows stakeholders to adapt progressively to the new requirements.

As SMEs, we are very concerned about the developments regarding the DPP. The need to involve a service provider for the DPP only contributes to further increased costs, which are ultimately passed on to consumers. Costs will be less important for large companies due to higher volumes and will lead to an increased imbalance.

Filed in German · English published by the European Commission

Hello, I wish to comment that 1 company may not be able to provide all this as a singular company. Forexample : (ii) creating the data carrier -- is a Label suppliers business. The DPP service providers main activities should be all these: : (i)creating the DPP; (iii) registering the DPP; (iv) hosting (storing) the DPP query service in relation to the DPP; (vi) enabling updates of DPP information; (vii) DPP…

The DPP infrastructure should be aligned with the data that can be collected upstream. Upstream data collectors should be involved to ensure data collected can be easily integrated, maintained and communicated to stakeholders within the EU market by the service provider. A DPP service provider should be able to show its ability to receive the upstream data.

THE ONLY WAY TO ENGAGE SME's and any Economic operator to embrace ESPR & DPP system at large scale and in the meantime avoid a kind of monopoly from big IT SaaS company require two things: 1) DPP provider should be on open source with full interoperability bteween ITsystem.... this would secure competitive pricing for DPPas aservice providers users...

Whilst supporting Digital Product Passports, I think the EC need to fully own the platform to provide these, or alternatively put it into the capable hands of CEN/CENELEC to own. If this is allowed to go to market, with various providers of platforms, I fear that this will lead to incompatibility of how data is transferred between platforms and give operators the licence to charge whatever they want for the use of…

The Commission wishes (in principle usefully) to lay down, by means of a delegated act, the conditions for digital service providers which (1) economic operators responsible as service providers (compulsory service providers) wish to provide their own digital product passports (mandatory under Article 10/3/b. and Article 75 et seq.

Filed in German · English published by the European Commission

The service operator providing ESPR/DPP data set's should basically work on a non for profit. Meaning that it should cover the operationnal+investment costs but not make profit beyond that. The commission did not launch this so that a company can make big money out of it but launched it in order to implement circular business models and empower the consumer. It should not become a financial burden.

It is widely acknowledged that the implementation of the Digital Product Passport (DPP) as a key element of product management within the circular economy represents a step towards greater transparency, efficiency, and sustainability. However, to achieve these intended goals, it seems reasonable that the implementation of DPP should be preceded by a detailed processes analysis.

Many thanks for having the opportunity to give feedback on this topic. As a SME service provider in the field of hazardous chemicals, the creating of DPPs will be obligatory for a wide range of client product portfolios, such as detergents, construction materials etc. Additionally current legislative updates e.g.

The Finnish Auto Discharge Union sees the introduction of the product passport as a generally good trend, which also contributes to supporting the re-use of vehicles in line with the circular economy regulation.

Filed in Finnish · English published by the European Commission

Digital Product Passports may provide a substantial benefit to the public, NGOs and governments provided the execution is done correctly. There remain significant problems in getting accurate data around the true origin of many materials and fibers from which products covered by EPR legislation and DPP requirements are made.

A single traceable minimum and maximum price per unit should be established to prevent price dumping or unfair competition from DPPSP. It should also be seen that the certifying body would give the certification stamp to the PPSD’s (ISO or the European Union itself).

Filed in Spanish · English published by the European Commission

Ladies and Gentlemen, the company for which I am working, is a small company in the printing ink industry. I work as a freelance worker and focus on regulatory matters. Any additional burden on the company should be kept to a minimum, otherwise it jeopardises competitiveness. If necessary and possible, we will try to meet the requirements with the least effort and create DPP somehow ourselves.

Filed in German · English published by the European Commission