Consolidated within the framework of the Ecodesign for Sustainable Products Regulation and already present in sectoral regulations such as that on batteries, the Digital Product Passport (DPP, for its acronym in English) is one of the European Union’s major bets to modernize the functioning of the Single Market.
For the consumer, it will translate into a digital support linked to the product from which they will be able to consult certain information about what they are buying. But its function will be broader: it will also have a regulatory dimension, within a system of compliance and market surveillance that is increasingly digitalized. The debate surrounding the initiative of the European Product Law also reinforces its horizontal vocation and raises how to integrate these tools in different sectors.
The question, therefore, is no longer whether we should digitalize European product policy, but how to do it so that the DPP simplifies compliance and contributes to more effective market surveillance. To that end, its design will have to avoid new duplications and digital silos, false appearances of conformity and disproportionate burdens for companies and Administrations.
A complete passport does not by itself prove that the product complies
The DPP can facilitate formal checks, such as verifying that certain information is available or associated with the product. That does not by itself prove that the information is accurate or that the product complies with the applicable requirements. When necessary, the authority must contrast the declarations with the documentation or evidence that supports them.
The difference also matters for fair competition. A complete DPP should not be treated as automatic proof of conformity: doing so could equate the operator who maintains reliable and traceable data with one who uploads information that appears complete, but without sufficient backing.
The problem is not solved either by incorporating more information into the DPP. More data does not necessarily imply better control. If the DPP entails excessive information or information only weakly linked to the objective of an inspection, locating, interpreting and verifying what is truly relevant may become more complicated. The value of the passport for market surveillance does not lie in becoming an exhaustive file for each product, but in supporting more agile and better targeted checks.
In this new environment, market surveillance must continue to be selective and risk-based, concentrating resources on the products, operators or possible non-compliances that require greater attention. The DPP must serve as a support tool for those controls, not replace them.
Digitize to simplify, not to duplicate
At a time when the European Commission has placed simplification and the reduction of burdens at the center of its agenda, the DPP should respond to that same logic and not add new documentary layers.
To this end, a distinction must be made between the information that must appear in the DPP and the supporting documentation (such as certifications, test reports or other evidence elements) that operators must retain and make available to the authorities when they require it. Without prejudice to the documents that the regulations require to be included or linked, systematically incorporating all this documentation into the passport would turn the DPP into a permanent repository of compliance files, even when that evidence were only necessary for a limited part of the controls.
The criterion of necessity must also be applied to each mandatory data item. Digitalization can reduce certain administrative burdens and speed up data exchange, but it does not make the information free. Each piece of data must be obtained, correctly linked to the product, structured, updated, protected and retained for the applicable period. This impact is especially relevant for SMEs, which have fewer resources to absorb the fixed costs associated with new technological infrastructures, management systems and regulatory obligations.
Each new requirement should therefore respond to a specific purpose and to a clearly identified use case. The question should not be what information we can digitize, but what information we need, for what purpose and who needs to use it. Not all users require the same data or the same level of detail.
Companies and authorities must move at the same pace
Once the obligations are defined, their implementation will require preparation on both sides of the system. Companies will have to adapt their processes and infrastructures, but the authorities will also need to have the necessary means to act in an increasingly digital regulatory environment.
The authentication of operators, the management of access rights, cybersecurity and the secure exchange of information require public infrastructures, specialized resources and continued maintenance. Therefore, the new business obligations should be deployed in step with the administrative capacities necessary to use them. Requiring compliance without that preparation would limit the practical value of the transformation and generate costs without the corresponding regulatory benefit. Therefore, sufficient adaptation periods, sector-specific guidelines and training for SMEs are necessary.
Connecting systems to avoid duplications
The DPP will be part of a European environment that already includes registers and platforms with different objectives. To reduce burdens, interoperability must make it possible for systems to exchange and interpret data with common identifiers, definitions and formats. Companies should not have to re-enter and maintain the same information in several channels when it can be safely reused. In addition, technological neutrality and existing investments should be preserved, with stable specifications and the possibility of changing provider without losing data.
Interoperability does not require gathering all regulatory evidence in a central database. It requires that the relevant systems be able to locate the information, recognize its meaning and apply the corresponding access permissions.
The DPP, an instrument at the service of compliance and competitiveness
The DPP will be useful if it responds to concrete needs: offering the user the relevant information, facilitating compliance, repair and recycling, and helping to guide effective controls. Its success will depend on requirements being clear, proportionate and compatible with existing systems, and on the available data being reliable.
The goal is not to digitize for the sake of digitizing: it is to facilitate compliance and improve oversight without multiplying procedures. Well designed, the Digital Product Passport can contribute to more efficient compliance, strengthen fair competition and favor a more competitive Single Market. For Spain's productive fabric, it should make it possible to certify the value of its products and open opportunities in repair services and material recovery, with an implementation accessible to smaller companies.