Joint statement on the Draft Standardisation Mandate on Digital Product Passport

In the context of the European Commission Draft Standardisation Request on the Digital Product Passport (DPP), we, representatives of ten associations, are concerned about the provisions requiring the data carrier to include six cross-sectoral basic data elements that can be consulted offline: (I) DPP owner; (ii) unique operator identifier; (iii) facility identifier; (iv) unique product identifier; (v) additional product identifier (optional); (vi) and product group (information on the type of product).

Recommendations:

To minimise overpackaging and maintain the readability of data carriers, while still allowing for DPP users to access basic information offline, we recommend that:

1. Only the Unique Product Identifier (UPI) is encoded in the data carrier.
2. All the other cross-sectoral basic data can be either accessible on pack or through the Product Passport Registry:
- The information on the DPP owner is present on pack;
- The facility identifier can be easily traced back from the UPI. Through the Product Passport Registry managed by the Commission (Art. 12 of the ESPR), users can access the unique facility identifier associated with the UPI encoded in the data carrier;
- The information on the product group can be easily identified from the packaging, in accordance with the Consumer Rights Directive.

We call on the European Commission to address the above concerns and amend the Standardisation Request on the DPP to ensure the readability of the data carrier and avoid unnecessary costs and complexities for economic operators.

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