Vetta Advisory is an independent consultancy that advises economic operators on digital product passport and EU product-data obligations. We do not sell passport software, identifiers or data carriers. Our comments cover only Article 2(1) and Annex II(3) of the draft. 1. Common standards for the battery passport and ESPR passports We welcome the reference to EN 18219:2026 and EN 18220:2026 in Article 77(3).
VA
Vetta Advisory
Company · France
not in the EU Transparency RegisterThis organization files on consultations without a register number, so its record here is built from its filings alone. Register facts (staff, costs, accreditations) are not available for it.
2
positions filed
in the 687 files tracked
2
legislative files
of 687 tracked
0
with a full position paper
attached to a submission
Counts here are a floor, never a total: they cover the 687 consultation files tracked so far (60,344 submissions, mostly 2021–26), so an organization's real filing history is larger, not smaller.
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Their record over time
Vetta Advisory filed 2 positions on 26 Oct 2026, across 2 of the 687 legislative files tracked here.
What they argued
Vetta Advisory is an independent consultancy on digital product passports and EU product regulation, based in France. We do not provide passport software and have no commercial ties with passport providers. We support the draft and its purpose-based approach. Our comments are requests for clarification on how it will work in practice for the economic operator that has to apply it. 1. Proving entitlement.
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Turns up on the same files
Organizations that also filed on at least two of the same consultations. A shared interest in the same dossiers, not evidence of coordination, and we do not suggest any.
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