Digital Product Passport Registry (DPP)

ESOP Associação de Empresas de Software Open Source Portuguesas (Business Open Source Portugal) is a non-profit trade association established in 2007, representing providers of products and services and other stakeholders of the Portuguese Open Digital Ecosystem.

The Digital Product Passport (DPP) registry draft implementing act represents a crucial step in defining the core architecture for the trusted digital infrastructure needed to support efficient product markets in the EU.

Bitkom supports the establishment of Digital Product Passports and welcomes the draft implementing regulation on the DPP Registry as an important step towards a functioning European DPP infrastructure. The draft provides a useful basis for implementation, but several aspects require further clarification to ensure legal certainty, cybersecurity, operational resilience and practical scalability for companies.

REFPIN welcomes the draft implementing regulation on the Digital Product Passport Registry and refers to its full PDF submission for the detailed feedback. REFPIN supports the creation of a European registry as a robust and well-documented core infrastructure.

Joint Regen Studio × CircularTech Forum submission. The decentralised registry-as-bridge spanning ESPR DAs, batteries, CPR, TSR, DSR is sound. Eleven asks to sharpen specific provisions. 1. Registration API explicit free-of-charge. Art 12(7) makes the semantic repository free; Art 3(b) is silent on the registration API. Make it explicitly free in Art 8 or Art 21 SMEs + non-EU operators need cost-certainty. 2.

We welcome the draft Implementing Regulation as a key building block for the DPP system, and particularly its provisions on automatic verification, semantic conformity, versioning, qualified electronic seal, timestamping, and a DPP-version hash. These are essential for a decentralised, modern DPP architecture.

European Construction Chemicals (ECC) suggests suggest to adjust the implementing act to allow for asynchronous uploading or an off-line fallback mode. Manufacturers should be allowed to assign local unique identifiers on the production line and synchronize them to the central EU register later, rather than requiring a life synchronous digital handshake for every single item produced.

Sika welcomes the opportunity to submit our feedback regarding the draft Implementing Regulation for the Digital Product Passport (DPP) Registry. Optimizing the operational viability, resilience, and predictability of the DPP registry is crucial for ongoing business activities and supply chain continuity.

The Policy Hub Circularity for Apparel & Footwear, thanks the European Commission for the opportunity to contribute to the final shape of the implementing act on the establishment of the Digital Product Passport (DPP) Registry.

4TheRecord GmbH, a digital product passport consulting company, welcomes the draft Regulation, which represents an important step towards operationalising the Digital Product Passport (DPP) framework and, in doing so, contributes significantly to the transition towards more sustainable products.

Forum STEM is a nationwide science and education initiative bringing together young people, students, experts, academia, business representatives and public-sector stakeholders around the future of science, technology, engineering and innovation.

Technology Industries of Sweden welcomes the European Commissions initiative to establish a Digital Product Passport (DPP) Registry as a core element of the Ecodesign for Sustainable Products Regulation (ESPR). A well-functioning registry is essential for enabling the DPP system in practice.

Sika welcomes the Regulations objectives but highlights structural criticalities in the proposed architecture: I. REGISTRY FAILURE SHALL NOT BLOCK THE MARKET Products should be able to be placed on the market by Economic operators with compliant DPPs when/if the registry is not available for external disruption or scheduled maintenance. II.

ANIVEC, representing the Textile and Clothing Industry (ITV) in Portugal made up mostly of SMEs focused on the nearshoring model, supports the EU’s sustainability and digitalisation goals. However, it warns that the proposed Implementing Regulation has serious shortcomings in customs supervision and imposes a disproportionate technical, economic and legal burden on European businesses, threatening a level playing…

Filed in Portuguese · English published by the European Commission

We recommend that the future Digital Product Passport Registry framework explicitly considers interoperability with existing Union and Member State registry systems that already perform comparable traceability and attribute-accounting functions.

Danish Chamber of Commerce (DCC) welcomes the establishment of the digital product passport (DPP) registry under Regulation (EU) 2024/1781 and as such support the establishment of a functional and secure registry that can facilitate compliance, improve market surveillance, and support a more level playing field across the Single Market.

The European Signature Dialog (ESD) brings together leading companies providing qualified trust services to more than 250 million users across Europe in their everyday digital interactions. ESD promotes secure, trustworthy, and interoperable digital services in line with the highest European standards.

We are grateful for the opportunity to comment on the draft Implementing Act and have provided feedback in the attached. We hope that the Act can: -Ensure the regulation is properly adapted to the requirements of the Toy Safety Regulation. -Clarify the possibility of the bulk registration of DPPs. -Ensure that access rights for bad actors can be revoked.

GS1 welcomes the European Commissions draft Implementing Act for the Digital Product Passport (DPP) Registry under Regulation (EU) 2024/1781 and appreciates the opportunity to contribute to this consultation. The development of the DPP Registry is an important step towards enabling a harmonised and interoperable framework for the exchange and management of product information across the EU Single Market.

The European Calcium Silicate Producers Association (ECSPA) welcomes the draft Implementing Regulation as an important step to also implementing the DPP system for construction products under Regulation (EU) 2024/3110 (CPR) and takes the opportunity to comment via the attached file.

CNA identifies some main concerns regarding the draft Regulation on the DPP Registry. The document raises concerns about the long-term availability and lifecycle consistency of DPP data, particularly when economic operators are no longer active or their verification expires. It also highlights the absence of clear technical and operational mechanisms governing backup copies and recovery procedures for DPP data.

The European Commission's draft implementing regulation for the Digital Product Passport Registry pursues a legitimate and broadly supported objective: establishing a uniform, secure and interoperable system for registering digital product passports across the European single market.

GODAN S.A. is a medium-sized Polish manufacturer and trading company specialising in balloons, party items and decorations. Our product portfolio covers a wide range of categories, some of which may fall within the scope of EU toy legislation. GODAN S.A. supports the objectives of the proposed framework, such as improved product safety and traceability.

Avery Dennison welcomes the proposed Implementing Regulation on the Digital Product Passport central registry as a key element of the EUs framework to enable product transparency, traceability and circularity. Establishing a central registry can support interoperability across product groups, facilitate compliance, and strengthen enforcement by providing a common reference point at EU level.

Michelin welcomes the draft implementing act establishing the DPP Registry and sets out in the attached file its key observations and suggestions, including aspects requiring clarification, specific considerations for tyres, and related recommendations. Michelin remains available to engage further following this call for evidence in support of an effective implementation of the DPP.

RDC Environment is a sustainable development consultancy that supports eco-organisations, public authorities and private companies on circular economy topics, including the battery passport. — The text does not provide for the possibility to register additional data fields voluntarily (excluding regulatory obligations) in the register and make them available (publicly or in a restricted manner).

Filed in French · English published by the European Commission

Bosch welcomes the opportunity to comment on the draft Implementing Act (IA) laying down the implementation arrangements for the digital product passport registry set up under Regulation (EU) 2024/1781. Given that the Digital Battery Passport (DBP) established under Batteries Regulation (EU) 2023/1542 will likely be the first Digital Product Passport (DPP) to utilise this registry, we offer our comments from the…

buildingSMART Nederland welcomes the development of the Digital Product Passport (DPP) ecosystem and recognises its strategic importance for sustainability, circularity and lifecycle information management within the built environment.

The Federal Association of Cooperative Small and Medium-sized Enterprises (BKM) welcomes the opportunity to comment on the draft implementing regulation establishing a DPP registry during the public consultation.

Filed in German · English published by the European Commission

The DPP in Fashion Working Group a multi-stakeholder initiative of the Institute for Sustainable Development and Environment at Lazarski University, Warsaw welcomes the European Commission's initiative to establish the Digital Product Passport Registry under Article 13 of Regulation (EU) 2024/1781 (ESPR) and strongly supports its underlying objectives.

The European Mortar Industry Organisation (EMO) welcomes the draft Implementing Regulation and the opportunity to provide feedback. EMO is concerned about the proposed mechanism for becoming a verified economic operator, which we consider overly burdensome in particular for SMEs and generally overly costly.

Aeiforo believes the underlying verification infrastructure (EU Digital Identity Wallet; equivalent routes for non-EU operators) will not be available on the Regulation's timeline. This risks blocking lawful EU market access for batteries, textiles and steel originating outside the Union.

The Federation of the European Sporting Goods Industry (FESI), representing around 1,800 manufacturers and 85% of the European sporting goods market, welcomes the European Commissions draft implementing act on the Digital Product Passport (DPP) Registry.

BEUC welcomes the draft implementing act to create the DPP Registry, as a means to operationalise the compliance of economic operators with their DPP obligations. Please find attached our comments to the draft, detailing our recommendations and rationale. We are happy to engage in discussions following this call for evidence in order to support a successful implementation of the DPP. Thank you and kind regards.

SPARE (formerly SIRRMIET) is a professional organization representing companies in France involved in the refurbishment and reuse of electronic, IT, and telecommunications equipment. It brings together companies operating across the entire value chain, from product collection and testing to their return to the market.

SBS, EBC AND SMEUNITED JOINT STATEMENT ON THE IMPLEMENTING ARRANGEMENTS FOR THE DIGITAL PRODUCT PASSPORT REGISTRY | Joint Statement attached | SBS, EBC and SMEunited welcome the opportunity to provide feedback on the implementing arrangements for the DPP Registry under the ESPR. The DPP Registry will play a central role in ensuring interoperability, accessibility and trust across the future DPP ecosystem.

Summary of comments attached. We strongly support the DPP as a key instrument under ESPR regulation for transparency and circularity across the EU single market. However, the following critical issues must be addressed for effective implementation, particularly in complex industrial sectors. 1. B2B/B2C Distinction.

ZDH-feedback on the draft implementing act on the DPP Registry: ZDH supports the establishment of a well-functioning registry. From a think small first-perspective, it considers amendments of several provisions essential to avoid SMEs will being disproportionately burdened. The skilled crafts sector in Germany counts around one million enterprises employing around 5,6 million staff.

EURATEX welcomes the Commission proposal establishing the Digital Product Passport (DPP) Registry under the ESPR framework, at the same time, several clarifications are needed to ensure proportionality, legal certainty and operational feasibility for the European textile and apparel ecosystem, which is largely composed of SMEs.

Fairly Made is a French DPP service provider operating a SaaS platform for supply chain traceability, LCA/PEF and DPP deployment. We serve 100+ brands, have issued DPPs for 100M+ products, and participate in 8 CEN/CENELEC JTC24 standardisation groups. Our feedback is attached in full; key points below. 1.

ACEA takes note of the publication of the draft Implementing Act on the DPP registry. While the draft provides an initial framework for the future functioning of the registry and its interaction with the Battery Passport under Regulation (EU) 2023/1542, a substantial number of legal, technical and operational aspects remain insufficiently clarified at this stage.

See understanding and improvement suggestions/feedback in attached file for the following topics: 1. Clarity on Service Provider's Role in Registration 2. Verification Process for Service Providers Managing Multiple Economic Operators 3. Early Access and Roadmap for Registration API and Semantic Repository 4. Data Deletion Process and Responsibilities 5.

EUREFAS broadly welcomes this draft Implementing Regulation as a necessary and well-structured step towards operationalising the Digital Product Passport framework. The registry architecture, the tiered access system, and the inclusion of value chain actors as legitimate DPP updaters reflect a sound understanding of how products circulate across the economy.

Comment on Article 8(1): For digital product passports registered at the level specified in the applicable delegated acts (e.g. model or batch), but issued at a finer granularity (e.g. item), and where the batch and model identifiers are linked to the item level digital product passport according to Article 8(3), there should not be a requirement to register each individual item level digital product passport in the…

We welcome the opportunity to provide comments on the draft implementing act establishing the Digital Product Passport registry under Regulation (EU) 2024/1781. We support the objective of the DPP framework to facilitate the digital exchange of product-related information across the value chain, improve transparency and to contribute to more efficient and harmonized data flows in the internal market.

RECHARGE welcomes the Digital Battery Passport (DBP) as it represents a key instrument to transparently showcase harmonised sustainability data collected across the entire battery value chain. As the first Digital Product Passport (DPP) to be implemented in Europe, the battery industry welcomes the DBP as an important step towards digitalising value chain information and supporting the transition to a circular…

With regard to defining the level of application of the Digital Product Passport (model, article or batch), we believe that greater attention should be paid to the specificities of the textile sector. In fact, the textile and fashion sector is characterised by high seasonality, collections with short life cycles and significantly lower market retention than other industrial sectors.

Filed in Italian · English published by the European Commission

Eurochambres supports the objective of delivering a secure and interoperable Digital Product Passport (DPP) Registry, representing a key pillar in the successful implementation of the DPP and in fostering circularity more broadly. However, its success will depend on whether companies of all sizes, especially SMEs, can use it in practice without disproportionate administrative or technical effort.

Digital Business Irelandis the leading and most active voice for Irelands digital and ecommerce sectors. Digital Business Ireland represents a community of over 8,000 businesses from multinationals to Irish SMEs, and experts in law and academia.

Ecommerce Europe welcomes the opportunity to provide feedback on the draft Implementing Regulation laying down the implementation arrangements for the digital product passport registry under the Ecodesign for Sustainable Products Regulation. The registry holds the potential to facilitate enforcement and support the compliance of economic operators and other value chain actors.

FEAD welcomes the Commissions work to establish the Digital Product Passport (DPP) Registry under Regulation (EU) 2024/1781. The DPP can become an important tool to improve transparency across value chains, support safer treatment and recycling, and facilitate the transition to a circular economy.

Namirial S.p.A. welcomes the opportunity to provide feedback on the draft Commission Implementing Regulation laying down the implementation arrangements for the Digital Product Passport Registry set up under Regulation (EU) 2024/1781 (Ref. Ares(2026)4424976 of 29 April 2026).

We fully endorse the European Unions goals to enhance traceability, transparency, and market surveillance, the implementation of the Digital Product Passport (DPP) must be realistic and manageable for small and medium-sized enterprises (SMEs). This is particularly crucial for businesses operating in consumer product sectors that are highly diverse, seasonal, and reliant on global supply chains.

The Right to Repair Europe coalition represents over 190 organisations from 30 European countries. It includes environmental NGOs and repair actors such as community repair groups, social economy actors, spare parts distributors, self-repairers, repair and refurbishing businesses, and any citizen who would like to advocate for their right to repair.

NVTB supports the establishment of a European DPP Registry, provided it is designed as a federated trust, registration, routing, verification and enforcement layer, not as a central EU product database. Product data should remain at the source, with manufacturers, authorised service providers, sectoral gateways or data platforms, and should be made accessible through interoperable dataspace frameworks such as DSGO.

The European Commissions Draft Implementing Regulation laying down the implementation arrangements for the Digital Product Passport (DPP) Registry and Definition Repository is a highly positive development for interoperability.

Please find out detailed feedback attached. We welcome the consultation for the creation of the DPP registry under the ESPR. Our main recommendation is that the implementing act is designed with the upcoming European Product Act in mind, and particularly the Market Surveillance Regulation, and its potential recommendations to tackle direct non-compliant product imports from non-EU manufacturers.

Independent Retail Europe supports initiatives to improve product transparency and consumer information through the Digital Product Passport (DPP), but we stress that the system must remain practical, proportionate, and manageable for retailers, especially SMEs. The DPPs should be linked by default to product models.

Regarding the backup copy obligation, for companies that plan to create and host their own DPPs, the Regulation should explicitly allow the backup obligation to be met using EU sovereign, enterprise grade cloud infrastructure operated by the manufacturer. Logically and administratively separated EU cloud environments can provide full continuity without forcing outsourcing to external backup hosting providers.

Regarding verification of the economic operator, requiring qualified signatures and seals for every legal entity creates disproportionate administrative and financial overhead for multinational manufacturers. Suggested to allow group level/corporate level verification and routine registry access via substantial level eIDAS after initial onboarding.

Regarding EU-resilient data storage and continuity, the regulation should clarify that DPP data and backup copies must remain continuously accessible to EU market-surveillance authorities, notified bodies and other authorized actors throughout the required passport lifetime.

Regarding trust and assurance of DPP service providers, the regulation should clarify minimum trust requirements for DPP IT/service providers to prevent the Battery Passport from becoming a static datasheet behind a QR code.

The TÜV Association welcomes the European Commissions draft Implementing Regulation laying down implementation arrangements for the Digital Product Passport registry under the Ecodesign for Sustainable Products Regulation (ESPR).

The proposed DPP registry introduces an additional centralized registration requirement alongside existing regulatory frameworks and registries, such as those within the context of Extended Producer Responsibility (EPR).

Portuguese companies, particularly SMEs, may face several challenges in implementing the DPP registry requirements. Key constraints include limited digital maturity and fragmented IT systems, creating difficulties in integrating APIs and new digital infrastructures.

Construction Products Europe argues that products with compliant Digital Product Passports should still be placed on the EU Single Market if the registry is temporarily unavailable. It calls for a limited registry focused on identifiers and DPP existence, with validation restricted to basic header metadata, while avoiding unnecessary costs and burdens, especially for SMEs.

The DPP Registry Implementing Regulation establishes a horizontal framework to enable product traceability, transparency and circularity across the EU. REMHub, a Horizon Europe funded initiative, considers it a key enabling infrastructure for rare earth element (REE) and critical raw material (CRM) value chains, with strong potential to improve material traceability, support recycling and enhance the visibility of…

EBC welcomes the establishment of the DPP Registry as an important step towards the implementation of the wider DPP framework. At the same time, it is essential to ensure that the future system remains proportionate, operationally feasible and accessible for SMEs, including construction SMEs under the revised CPR.

ECOS welcomes the proposed implementing act for the Digital Product Passport (DPP) Registry. There is a need for a publicly accessible platform, on the model of the EPREL database, for all to be able to find existing DPPs, as an entry point alternative to the data carriers that can be found on products themselves.

Polish Steel Association (HIPH) emphasizes that the Digital Product Passport (DPP), together with the related registry, must be designed and implemented in a manner that ensures that the scope of data collected and processed is strictly limited to information genuinely necessary for the attainment of the applicable regulatory objectives.

Fecc welcomes the opportunity to comment on the Digital Product Passport (DPP) Registry and supports its objectives under the ESPR. It highlights the importance of clear terminology and a strict separation of roles and responsibilitiesparticularly between data originators and data handlersto avoid unintended liability shifts to distributors.

The European Balloon & Party Council (EBPC) welcomes the opportunity to provide feedback on the proposed Implementing Regulation establishing the Digital Product Passport (DPP) Registry under the ESPR framework.

FEICA welcomes the opportunity to provide comments on the draft implementing act establishing the Digital Product Passport (DPP) registry under Regulation (EU) 2024/1781. We support the objective of the DPP framework to facilitate the digital exchange of product-related information across the value chain, improve transparency, and contribute to more efficient and harmonised data flows in the internal market.

As one of the largest global sporting goods manufacturers and retailers, Decathlon sees the Digital Product Passport (DPP) as a powerful sustainability accelerator, as well as an important step towards greater transparency and traceability. However, to ensure the market and technical viability of the central DPP Registry, the implementing framework must remain practical, secure, and proportionate.

Private enforcement is an important cornerstone in the enforcement of existing rules. In order to enable civil society organisations to conduct proceedings through private enforcement, they should have access to the DPP registry.

Filed in German · English published by the European Commission

The German Federal Institute for Research on Building, Urban Affairs and Spatial Development within the Federal Office for Building and Regional Planning, Division WB 6 Instruments for resource-saving and climate-adapted construction, would like to comment on the draft Implementing Act for the Digital Product Passport Registry, with a particular focus on the Construction Products Regulation (CPR) (EU) 2024/3110 and…

The European Association of Motorcycle Manufacturers (ACEM) welcomes the possibility of submitting written feedback to the public Have your say consultation, due on the 27th of May 2026, regarding the draft Implementing Act for establishing a DPP registry according to Article 13(1) of 2024/1781. The motorcycle industry remains available to collaborate closely with the European Commission and the Stakeholders.

Tyres Europe reaffirms its commitment to a circular and sustainable mobility sector. However, the successful rollout of the DPP Registry relies on a practical, secure, and technologically cost-effective design. It is crucial that the DPP framework is based on a solid foundation, enabling transparency and digitalisation without compromising efficiency.

Article / Provision: P.2 (4) & Others Unique Identifiers Proposed Amendment / Comment: The regulation should clearly state that any unique identifier design is permitted as long as it complies with international standards, such as ISO/IEC or GS1 Digital Link, and ensures interoperability.

Aura supports the establishment of a Commission-managed DPP Registry as a key enabler of trusted, traceable and enforceable Digital Product Passports. For the Registry to be successful, it should be technically scalable, legally clear and operationally workable for economic operators and their DPP service providers.

BASF welcomes the initiative of the European Commission to develop a harmonised, fit-for-purpose and consistent framework for the interoperability and efficiency of Digital Product Passport (DPP). The current draft implementing decision highlights the risk that the EU may weaken its own industrial competitiveness by introducing increasingly detailed and complex regulatory requirements.

Feedback: Digital Product Passport Registry Key Compliance Observations Enphase Energy welcomes the European Commission's initiative to establish a Digital Product Passport (DPP) Registry under the Ecodesign for Sustainable Products Regulation (ESPR). We are committed to the transparency and sustainability objectives underpinning the DPP framework.

The European Furniture Industries Confederation (EFIC) welcomes the opportunity to provide input to the consultation on the draft Implementing Regulation laying down the implementation arrangements for the digital product passport registry under the Ecodesign for Sustainable Products Regulation (ESPR). The attached paper presents our recommendations to address the identified issues.

These comments are submitted from the perspective of an organisation supporting battery manufacturers in DPP readiness, supplier data mapping, evidence collection and carbon footprint preparation. The concern is not the creation of the DPP Registry, but the need for clearer rules on roles, validation and SME participation in battery supply chains.

The draft establishes a mandatory, formal, and audit-proof accreditation system for companies, with stringent requirements regarding identity verification, data quality, technical interoperability and requirements for IT security. However, it appears getting started with the register sounds relatively easy apart from still unclear definitions.

The Spanish Chamber of Commerce has set out a series of considerations and observations designed to promote implementation that is proportionate, technically feasible and in line with the operational reality of the business fabric for the operation of the Digital Product Passport register, in implementation of Regulation (EU) 2024/1781 on the ecodesign of sustainable products.

Filed in Spanish · English published by the European Commission

UL Solutions feedback on the draft Implementing Regulation for the Digital Product Passport Registry We welcome the Commissions work to establish the Digital Product Passport (DPP) registry and its core components, including the API, semantic repository and secure access framework. We support in particular the objective of interoperability through a common semantic repository with publicly documented interfaces.

Article 4(4) Dual periods of validity are mentioned here. Either until the expiry of the electronic identification means or up to 3 years after the date of verification. This means that companies always have to monitor two points in time, which is a disproportionate effort. Please request only a period of time, e.g. until the expiry of the electronic identification means under Article 7(3) and (4).

Filed in German · English published by the European Commission

IECA (Instituto Español del Cemento y sus Applicaciones) considers that in construction products it is essential that this framework is consistent with Regulation (EU) 2024/3110 (CPR), its documentary obligations and the factory production control systems. Otherwise, duplications, diverging interpretations or administrative burdens could arise in continuous manufacturing or bulk products.

Filed in Spanish · English published by the European Commission

S1Seven welcomes the draft Implementing Regulation as a necessary step toward operationalising the Digital Product Passport. The attached response sets out ten specific concerns and recommendations, informed by the FprEN 1821618246 standards developed under JTC 24 and by sectoral experience with intermediate steel DPPs.

We would like to draw attention to the need to clarify several issues and provide further information: 1. No deadline specified for DPP registration in the system the draft regulation does not specify by when the digital product passport must be registered in the register in relation to the date on which the product is placed on the market.

The Fair Trade Advocacy Office (FTAO) welcomes the Commission's initiative to establish the technical architecture for the Digital Product Passport (DPP) registry under Regulation (EU) 2024/1781 (ESPR). The registry will form the operational backbone through which product sustainability data flows across global supply chains.

European Aluminium, the association representing the full aluminium value chain in Europe, welcomes the European Commissions consultation on the Digital Product Passport Registry. The Ecodesign for Sustainable Products Regulation (ESPR) can help facilitate a smooth and accelerated transition towards a circular, resource-efficient, and low-carbon economy, while contributing to the EUs Green Deal sustainability…

MAHLE Position on the DPP Registry The Digital Product Passport (DPP) has the potential to impose significant efforts and costs on the economy. While MAHLE strongly supports transparency for consumers and customers, the automotive industry already operates under several regulations ensuring transparent access to component data the MAHLE spare parts catalogue being one example.

1. About amfori amfori is a global business association supporting over 2,400 companies in improving their ESG performance across international supply chains. With over 20 years of expertise, we help businesses strengthen responsible sourcing practices and mitigate risks.

We welcome the European Commissions Digital Product Passport (DPP) initiatives and strongly support the creation of a harmonised and interoperable DPP ecosystem across Europe. Based on input gathered from stakeholders in the Dutch built environment, digiGO highlights the importance of enabling the registry of assembled products and bill-of-material linkages within the registry, while ensuring interoperability across…

The European Pirate Party welcomes the opportunity to respond to the draft Implementing Regulation for the Digital Product Passport Registry. While we support the DPP system and its sustainability objectives under Regulation (EU) 2024/1781, the draft establishes a centralised identity and logging infrastructure that processes extensive personal data across the Union.

The registration of products in the Central Registry should remain free of charge, and it is important to ensure that this principle is maintained. When referring to a product in the construction products sector, it is essential to clarify whether this means a product family (sharing the same general characteristics and intended function) or an individual product identified by a specific article code.

BFH Feedback on the Digital Product Passport Registry The Bern University of Applied Sciences (BFH) strongly supports the Commissions initiative to strengthen circular economy measures through the Digital Product Passport (DPP) registry. Our institution has participated in several EU projects to enhance the development of the Digital Product Passport specifically for the photovoltaics (PV) sector.

Tata Steel Nederland welcomes the opportunity to provide feedback on the draft regulation concerning the Digital Product Passport (DPP). We support the overall objective of improving transparency, traceability and access to relevant product-related information across value chains.

The RAIN Alliance welcomes and supports the European Commission's initiatives on sustainable products, digital product passports (DPPs), and their central registration prior to being placed on the European market.

VALTYROL FlexCo is an independent data-strategy consultancy from Tyrol, Austria. We help SMEs prepare for the Digital Product Passport. We are a Certified Value-Based Engineering Ambassador (ISO/IEC/IEEE 24748-7000) and write from the view of small and medium-sized companies, because they carry the highest relative cost of this regulation. 1.

EUROPEN has consistently highlighted the potential of the DPP as a tool to store relevant information and support digitalisation in previous consultation initiatives launched in 2025. Building on that initial input, we would like to take this opportunity to further complement our contribution through the present submission.

Knauf welcomes the opportunity to provide feedback on the Commissions implementing arrangements regarding the Digital Product Passport registry. With regard to Introduction (3), Knauf would appreciate further clarification on the terms commodity code and semantic repository, as their precise meaning and intended application in this context are not sufficiently clear.

The Austrian Furniture Industry welcomes the development of the Digital Product Passport (DPP) as a strategic instrument to support a more circular, transparent, traceable and competitive Europe, in line with the objectives of the Ecodesign Regulation (ESPR). A harmonised EU registry can bring important benefits in terms of interoperability, regulatory trust, market surveillance and consistency among stakeholders.

Product Ident GmbH supports the establishment of a secure, interoperable Digital Product Passport Registry under Regulation (EU) 2024/1781. The draft Implementing Regulation correctly identifies the technical pillarsAPIs, semantic repositories, and user verificationnecessary for operational success.

Under the Ecodesign for Sustainable Products Regulation, the Digital Product Passport (DPP) was introduced to provide easy access to digital information related to the sustainability, circularity and legal compliance of a product. This initiative will set out the implementing arrangements for the Digital Product Passport Register to be made available for public consultation on a European website.

Filed in Italian · English published by the European Commission

LightingEurope welcomes the publication of the draft Digital Product Passport Registry Implementing Regulation as it marks a significant step in the implementation of the Regulation (EU) 2024/1781 establishing a framework for the setting of ecodesign requirements for sustainable products (ESPR).

We welcome the overall approach of the draft Implementing Regulation, in particular the decentralised DPP model, the use of semantic validation, audit logging and the concept of a digitally verifiable proof of registration. Please find attached our remarks.

The European Federation of Premanufactured Building (EFV) thanks the European Commission for the opportunity to comment on this draft Implementing Regulation. EFV broadly welcomes the establishment of a centralised DPP registry and sees its members - industrialised building manufacturers - as well-placed to operate within this system.

As feedback regarding the consultation of the DPP Registry draft implementing act, we generally appreciate the effort to establish a scalable and interoperable framework for Digital Product Passports. The document raises several important considerations, particularly around governance, semantic interoperability, lifecycle management, and the handling of assessment-based construction products.

Digital Product Passport Registry - feedback The European Solar Manufacturing Council (ESMC) welcomes the European Commissions initiative to strengthen circular economy measures. As solar photovoltaics (PV) are poised to become Europes largest energy source, it is critical to address key gaps in PV sustainability.

RTE considers that two additional considerations should be reflected in the implementing regulation for the DPP registry: 1. The regulation should ensure the long-term availability and accessibility of DPP information.

Danish Industry (DI) represents more than 20.000 Danish companies across a range of industries. DI supports the ambition to establish a robust and interoperable system that can strengthen circularity, transparency and market surveillance in the EU. At the same time, DI highlights a number of key concerns that should be addressed to ensure effective implementation and industry uptake.

Feedback on the Draft Implementing Regulation for the Digital Product Passport Registry, Ares(2026)4424976 Talkpod welcomes the draft implementing regulation and supports the Commission's effort to give the DPP a workable backbone. We build the consumer and auditor facing layer that sits on top of passports.

We welcome the proposal and acknowledgement of the role of semantic modelling. This provides an excellent foundation for semantic interoperability for DPPs. However, we do have a number of points of feedback based on TNOs experience with the creation and governance of Semantic models, and decentralized data sharing architectures. We are available to support resolving our feedback as well of course. 1.

We reject additional administrative and financial burdens for companies. DPP services must be legislatively dedicated to the EU and the national authorities. It is unacceptable to create requirements for the purchase of any services in connection with DPP by legislation, or to create a completely new market for DPP services ( Recital 3, 4, 14, hereinafter Art. 3). Art.

Cement Europe welcomes the draft implementation act for the Digital Product Passport Registry. We would like to suggest using a simpler, easier to understand English as some sentences/paragraphs are hard to understand.

The current draft illustrates how the EU risks undermining its own industrial competitiveness through increasingly complex and granular regulatory requirements. The Digital Product Passport will become mandatory for a vast majority of products many of which are manufactured largely outside Europe.

Article 1(1) of this draft implementing regulation states that the unique identifiers of batteries covered by Article 77 of Regulation (EU) 2023/1542 will be registered and stored in the Digital Product Passport (DPP) registry. Vehicle batteries are included within the scope of this article. As such, the Netherlands Vehicle Registration Authority (RDW) wishes to share the following input: 1.

Ecocert is a specialist in environmental and social certification, with long-standing experience in verifying sustainability claims, supply chain practices, and product compliance through independent third-party assessment.

Glass for Europe, the trade association of the EU flat glass sector, welcomes the opportunity to comment on the draft Digital Product Passport (DPP) Registry implementing act. Flat glass products used in buildings will be required to have a DPP as soon as they are covered by the Construction Products Regulations of 2024.

IndustriAll Europe represents trade unions organising over 7 million workers across Europes manufacturing, mining and energy sectors, bringing together more than 200 affiliates in 39 countries. IndustriAll Europe welcomes the opportunity to provide feedback on the draft implementing regulation for the Digital Product Passport (DPP), a key instrument for operationalising the Ecodesign for Sustainable Products…

IVSH, representing the German speaking cutlery and household goods industry, welcomes the opportunity to provide feedback on the draft implementing regulation for the DPP registry. We support the overarching objectives of the Digital Product Passport. However: the DPP must clearly deliver added value in practice, unlock efficiencies and be SME friendly by design.

The German automotive industry supports the establishment of Digital Product Passports (DPPs) and promotes their benefits for industry and other stakeholders. VDA also welcomes the implementing regulation on the DPP registry. The published draft already reflects the main points and provides industry with guidance. However, we still see a few aspects that require clarification.

The Funtion of the Digital Product Passport should not be overburdend, but Focussed on key aspects following the needs of a Circular Economy. It should allow to map the urban mine and to replace existing reporting duties, to be a benefit for the Industry in Europe as the bedrock of Circular Eocnomy. Please see the full statement in the attachement.

Filed in German · English published by the European Commission

Swappie welcomes the publication of this draft implementing regulation as an important step in the operationalisation of the Digital Product Passport system under the ESPR. The regulation addresses critical infrastructure questions (incl.

The BatteryPass-Ready project strongly supports Digital Product Passports (DPPs) as tools to advance digitalization, circular economy business models, and administrative efficiency. We identified room for improvement regarding the current draft: Three overarching issues are highlighted: 1.

P&G supports the Digital Product Passport (DPP) as a practical tool to digitize product information requirements, improve transparency for value-chain actors, and simplify compliance for companies. To keep the DPP registry simple-by-design and workable for high-volume sectors, while avoiding unnecessary costs, we recommend the following: 1.

The draft Implementing Regulation should be complemented by an explicit reference to the DPP standards developed by CEN/CENELEC JTC 24. These standards cover the key technical and organisational elements of the DPP system, including identifiers, data carriers, data exchange protocols, APIs, system and semantic interoperability, storage, archiving, access rights, information security, business confidentiality, data…

ANEC supports the establishment of a secure and interoperable registry provided for in Article 13 of the ESPR. While the registry is not expected to be directly accessed by consumers, it will be fundamental to the quality and trustworthiness of the DPP information consumers will receive through the web portal provided for in Article 14 of the ESPR, product data carriers, and other authorised services.

Marklytics builds and operates digital product passport (DPP) software and already supports compliance with the EU Battery Regulation (EU) 2023/1542. We support the objective of a single, interoperable EU DPP Registry, but the implementing act should be clarified to ensure it is workable, secure, and scalable in production.

The Confederation of Swedish Enterprise welcomes the development of the Digital Product Passport (DPP) as a strategic tool to support a more circular, transparent, traceable and competitive Europe, aligned with the objectives of the Ecodesign for Sustainable Products Regulation (ESPR).

For: European Commission Draft Implementing Regulation on the Central Registry for Digital Product Passport (DPP) under Regulation (EU) 2024/1781 (ESPR) Submission of consultation responses with a particular focus on the unintended and disproportionate consequences that the implementation of the Distributor and Actor concept in the Regulation entails for the leasing and asset financing sector. 1.

Filed in Danish · English published by the European Commission

Feedback on the draft implementing act on the DPP Registry: The majority of carpentry businesses are organised as traditional craft enterprises. Nearly two thirds of businesses employ fewer than ten people, and around half are even micro-enterprises with fewer than five employees. This gives rise to specific challenges, particularly from a staffing perspective.

On behalf of the Arbeitskreis Marktüberwachung Bau (the administrative cooperation of the German federal market surveillance authorities for harmonised construction products), we would like to thank you for the opportunity to provide feedback on this initiative. As our comments relate to individual articles, we have compiled them in the attached table for the sake of clarity and readability.

As a Finnish SME in the machine manufacturing sector, we support the long term goals of the Digital Product Passport. However, the current requirements place a disproportionate burden on smaller companies with limited resources. We build roughly 200 fully customized units per year, each engineered to last for decades. This long lifetime means our business depends heavily on after market services.

Clean Clothes Campaign is a global network of trade unions and labour rights organisations working in the garment sector. Overall, we welcome the DPP registry as part of the ESPR. Transparency in supply chains is a necessary enabling factor for a fairer and more sustainable garment sector.

In implementing the Digital Product Passport (DPP), it is critically important to ensure that economic operators outside the EU are not placed at a disadvantage and that the requirements do not become more traderestrictive than necessary to achieve their intended objectives.

Polish Confederation Lewiatan, representing more than 4,100 companies employing over one million people, supports the establishment of the Digital Product Passport (DPP) Registry under the Ecodesign for Sustainable Products Regulation (ESPR). We consider the DPP an important tool to improve transparency, traceability and access to product information across the EU Single Market.

Irish Manufacturing Research (IMR), acting as the Secretariat of CIRCULÉIRE and on behalf of its members, welcomes the opportunity to contribute to the consultation on the Draft Implementing Regulation for the Digital Product Passport (DPP) Registry and to provide our views on the proposal outlined by the Commission.

We welcome the development of the Digital Product Passport (DPP) as a strategic instrument to advance a more circular, transparent, traceable, and competitive European industry, fully aligned with the objectives of the Ecodesign for Sustainable Products Regulation (ESPR). The document provides an exhaustive overview of the implementation arrangements for the DPP registry.

TEMU welcomes the opportunity to contribute to the consultation on the Draft Implementing Regulation for the Digital Product Passport (DPP) Registry and to provide our views on the questions and proposals outlined by the Commission. Please find our full response in the attached document.

EuroWindoor welcomes the opportunity to contribute to the public consultation on the draft Implementing Regulation on the Digital Product Passport (DPP) Registry. We recognise the value of a well-functioning registry for transparency, market surveillance and the circular economy.

The European Footwear Confederation (CEC) welcomes the objectives of the EU Digital Product Passport and the establishment of a common Registry as important steps towards greater transparency, traceability, and circularity in the internal market.

TecPart Verband Technische Kunststoff-Produkte e.V. (TecPart) welcomes the draft implementing regulation on the DPP Registry as an important basis for the technical implementation of the Digital Product Passport (DPP). However, TecPart recommends further clarification to ensure that the future system remains practical and proportionate for SME manufacturers, processors and recyclers of technical plastic products.

In imenu Sekcije tekstilcev ter Sekcije predelovalcev kož pri Obrtno-podjetniški zbornici Slovenije (OZS), ki Skupaj zastopata ključno jedro slovenskega malega gospodarstva na področju módne in predelovalne industrije (Kjer več kot 250 podjetij, predstavlja 70 % samozaposlenih obrtnikov, preostali del pa micro in mala podjetja), podajamo pripombe.

Filed in Slovak · English published by the European Commission

The Association of the German Water and Heat Meter Industry (VDDW e. V.) welcomes the benefits of the implementation of the Digital Product Passport Registry such as greater transparency and traceability, a competitive advantage through sustainability (replacing paper information by digital way), more efficient compliance, improved data integration in Industry 4.0 but also sees several risks: - High costs and…

We welcome the development of the Digital Product Passport (DPP) as a strategic tool to move towards a more circular, transparent, traceable and competitive European industry, aligned with the objectives of the Ecodesign for Sustainable Products Regulation (ESPR).

Filed in Spanish · English published by the European Commission

Suomen Autopurkamoliitto ry represents professional, licensed automotive dismantling and recycling operators in Finland. Our member companies process end-of-life vehicles in accordance with Directive 2000/53/EC (ELV Directive).

The DPP is the central instrument of the Ecodesign for Sustainable Products Regulation (ESPR) to pursue the goal of ensuring end-to end transparency about products throughout their entire life cycle from man-ufacturing to use, disposal, or reuse.

Identification and Security EK emphasizes that the reliability of Digital Product Passport (DPP) data requires strong identification and a high level of data security. The identity of the data provider must be verified using reliable identification methods, such as the Business Wallet solution. This is essential to ensure that the entity providing the data is indeed who it claims to be.

The main SME concern is that the draft may create a new administrative and technical compliance layer that is difficult for smaller companies to manage without external support. SMEs may first struggle to know whether they are in scope under Article 1, then face verification requirements under Articles 4 and 5, registration complexity under Article 8, technical validation errors linked to semantic conformity and…

The Maison Rostaing supports the introduction of the Product Digital Passport (DPP) under the ESPR Regulation, as a structuring lever to improve the transparency, traceability and circularity of products at European level.

Filed in French · English published by the European Commission

AWARE Digital Product Passport service provider working with textile manufacturers across Asia. We welcome the draft and the confirmation of a decentralised model. Recital 4 expressly contemplates digital product passport service providers as value chain actors who undergo verification and update passport data, and Recital 3 confirms service providers host backup copies. We support this structure.

The draft establishes a sound governance framework, but three gaps will affect implementation success. Each has a concrete suggestion. 1. Absence of data structure clarity. Articles 11 and 12 require all passport data to conform to models in a Commission semantic repository, and Article 11(1) commits to reusing existing EU-level semantic assets.

Aqua Metering, representing European manufacturers of water metering technologies, welcomes the European Commissions initiative to establish a Digital Product Passport (DPP) Registry as part of the Ecodesign for Sustainable Products Regulation (ESPR). We strongly support the objective of improving product transparency, circularity, and regulatory compliance through structured digital product data.

Green IT has been working for several years on digital sobriety, environmental analysis, eco-design, the circular economy, re-use and recycling issues, and resource sovereignty to steer digital towards practices that respect planetary boundaries.

Filed in French · English published by the European Commission

The Maritime Battery Forum is working with a group of stakeholders in the maritime industry on defining a practical approach to Digital Product Passports for maritime battery systems. We have identified several differences in terminology for batteries in other industries compared to maritime battery systems which can cause confusion in implementing a Digital Battery Passport.

As a textile and garment manufacture, we have below comments: (4) Regarding textile products and footwear, it is unclear what is meant by updating the data of a products digital product passport by actors such as repairers, refurbishers or recyclers.

The Polish Cluster of Composite Technologies (PKTK) supports the development of digital product passports as a tool for increasing the transparency of value chains, supporting the circular economy, and enabling reliable reporting of environmental data, including LCA and carbon footprint data.

As TechnoService S.A., a PCB manufacturer classified as an SME, we support the EUs sustainability goals but are seriously concerned that the proposed Implementing Regulation on the DPP Registry will significantly weaken the competitiveness of EU industry, especially SMEs, without clear benefits for businesses.

Caruma welcomes the Commissions initiative to establish implementation arrangements for the Digital Product Passport Registry. As a DPP technology provider, we support a secure, interoperable and decentralised DPP ecosystem.

Granularity and proportionality (Article 8) The draft implementing regulation does not provide sufficient clarity on the appropriate level of granularity (model, batch or item level) for the registration of Digital Product Passports (DPPs). For manufacturers of customised construction products, such as sectoral doors, this is a crucial point from an operational and organisational perspective.

Filed in Dutch · English published by the European Commission

The directive addresses ensuring data accuracy. However, from an engineering point of view, accuracy is a relative category since high accuracy costs effort. Therefore, in many cases data is not very accurate, but at least accurate enough for the intended application.

This draft act is of major importance for the biocidal products sector. We welcome the fact that the scope of ecodesign requirements also covers products contributing to the protection of the health of the general public, in particular products falling under type TP19 of the biocidal regulation.

Filed in French · English published by the European Commission

EQA welcomes the consultation on the Digital Product Passport (DPP) Registry as a key component of the Ecodesign for Sustainable Products Regulation. As an independent audit and conformity assessment body, EQA considers that the effectiveness of the DPP system will depend not only on technical interoperability, but also on the credibility, integrity, and verifiability of data.

IDnow GmbH, a certified Qualified Trust Service Provider (QTSP) under eIDAS, submits five comments on the draft Implementing Regulation for the DPP Registry. We address: (1) the role of QTSPs in the verification platform; (2) specification of required identification attributes for electronic attestations; (3) interoperability with existing EU systems (EPREL, customs); (4) data protection roles of QTSPs; and (5)…

I am submitting this feedback as a commercial operator active in the global secondary electronics market. My activities span B2B trading, R&D, device processing and grading, and wholesale distribution across Europe. My customers include refurbishers, wholesalers, retailers, and SMEs across the EU. This feedback reflects practical operational questions the current draft leaves unanswered for the secondary market. 1.

I disagree with this regulation for the following reasons: — The digital passport should be voluntary and not mandatory. Thousands of SMEs and micro-SMEs cannot be forced to increase their bureaucratic tasks significantly in exchange for an unclear consumer benefit.

Filed in Spanish · English published by the European Commission

As an eIDAS2 expert, I would like to underline 3 issues of this Implementing Act project (IA) regards to the level of trust, probative values and security targets for digital journeys - Issue 1 for the level of trust of initial onboarding for the verification process >>Reco1: I advise to request Qualified Electronic Attestation of Attributes (QEAA) for the same high level of trust guarantee.

Transpareo AG (Switzerland) is preparing to register under Article 3(f) as a Digital Product Passport Service Provider. We comment on the operational readiness of the registration API ahead of the 19 July 2026 launch. Article 3(b) requires the registry to provide an API for registering digital product passports and for receiving information from the registry.

Transpareo AG (Switzerland) is preparing to register under Article 3(f) as a Digital Product Passport Service Provider. We are concerned that Article 17 as currently drafted risks being read as restricting access to public DPP data, which would defeat the consumer-transparency intent of the ESPR.

Transpareo AG (Switzerland) is preparing to register under Article 3(f) as a Digital Product Passport Service Provider. Two related issues affect the long-term verifiability of registered DPPs by third parties. First, Article 9(4) caps registry-side proof-of-registration availability at 90 calendar days from generation, with regeneration on request.

Transpareo AG (Switzerland) is preparing to register under Article 3(f) as a Digital Product Passport Service Provider. The Implementing Regulation correctly establishes the decentralised model. Recital 3 states that "the digital product passport system is built on a decentralised model" and that "the registry should also include a reference list of digital product passport service providers which host backup copies…

Dear Sir or Madam, Overall, I believe the implementation of the Digital Product Passport should aim to: - make trustworthy product information easier for consumers to access; - make problematic, misleading or incorrect product information easier to report; - make it easier for economic operators to publish reliable, structured and tamper-evident product information; - create a positive feedback loop through market…

EUROLAB, a European association representing laboratories and other conformity assessment bodies, supports the Digital Product Passport (DPP) as a digital complement to the Ecodesign for Sustainable Products Regulation (ESPR) to consolidate compliance evidence, improve safety-relevant version control, and enable more effective market surveillance and circularity.