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.
HON
Honeywell
Company · United Kingdom
4
positions filed
in the 326 files tracked
1
legislative file
of 326 tracked
0
with a full position paper
attached to a submission
Counts here are a floor, never a total: they cover the 326 consultation files tracked so far (29,503 submissions, mostly 2025–26), so an organization's real filing history is larger, not smaller.
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Their record over time
Honeywell filed 4 positions on 27 May 2026, across 1 of the 326 legislative files tracked here.
What they argued
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.
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