July 1, 2025

Response to the European Commission public consultation on Digital Product Passport (DPP) service providers

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Orgalim, representing Europe’s technology industries, welcomes the opportunity to provide early input to the upcoming delegated act setting out requirements for Digital Product Passport (DPP) service providers in the context of Article 11.3 of the Ecodesign for Sustainable Products Regulation 2024/1781 (ESPR).


The ESPR leaves it open to economic operators responsible for making available a DPP to decide whether to store DPP data in their own systems or use third party services (Article 11.c ESPR). The choice will depend on each company’s assessment of the related costs and the necessary IT infrastructure, inter alia. It is expected that not all relevant economic operators, in particular many SMEs, will have the resources required to create, authenticate, process, store and maintain all DPPs in their own systems. In these cases, contracting the services of third party DPP service providers will be required.

To read our response in full please download the document above.

Authors

  
Francesco Guerzoni
Senior Adviser – Digital and Legal

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