JBCE and JP4EE Feedback on the Rules for Service Providers under the Digital Product Passport

On 10 December 2024, JBCE and the Japanese 4EE industrial associations (JP4EE) provided feedback on the rules for service providers under the Digital Product Passport (DPP).

In the position paper, JBCE and JP4EE note that:

• They support the creation of a mandatory certification scheme for DPP service providers. However, the certification scheme should apply only to DPP service providers, meaning that operators who choose to build the DPP internally should not be subject to this verification process.
• They request the European Commission to provide a clear definition of the essential scope for DPP service providers, as unified standards are key to simplifying compliance, avoiding vendor complexity, and ensuring alignment with other regions to support effective data collection and prevent consumer confusion.
• To ensure effective DPP implementation, minimal requirements should be set to prevent excessive burdens on SMEs, with reasonable fees and streamlined processes. Clarifying optional data use and enabling cost-efficient data exchange will support fairness, efficiency, and adoption.
• Ensuring information security is critical for DPPs. A clear governance framework is required, including guidelines for handling confidential information, protections against reverse engineering, and universal security standards with common guarantees and access protocols to establish trust between entities.
• The DPP must ensure compatibility with existing systems and support the interoperability of databases across countries and sectors. We would kindly request that the European Commission clarifies how it will enable seamless application for imported goods, ensure non-EU provider availability, and guarantee data continuity.
• A sufficient implementation period of at least 24 months is essential for the adoption of structured, machine-readable data under ESPR. The process involves lengthy adjustments, complex labelling updates, and challenges such as limited space, un-unified standards, and overlapping eco-label requirements.

For more information, please contact info@jbce.org