Digital Product Passport: Simpler, smarter, and built on what works

The home appliance industry welcomes the digitalisation of product information as a future proof, more flexible alternative to paper documentation and a sound basis for digital economy. However, this does not automatically justify a broad, mandatory Digital Product Passport (DPP) model as currently envisaged by the European Commission. Such DPP requires a significant effort, while the home appliance sector, currently supporting 1 million jobs and contributing significantly to the EU GDP, is under high competitive pressure. It is therefore essential that the digital transition remains fair, pragmatic, and grounded in the "start small" principle, following a strict assessment of added value and necessity for each new obligation. It must also ensure legal certainty, protect trade secrets, and avoid imposing obligations before the relevant regulatory and technical parameters are clearly defined. For our industry this means leveraging the already existing and recognised systems such as the European Product Registry for Energy Labelling (EPREL) for products carrying an energy label and creating a harmonised framework that ensures that if a product is already legally required to carry a QR Code, no additional data carriers are added for overlapping requirements.

Key Messages:

• Leverage existing infrastructures for the DPP, such as EPREL, to avoid duplicating systems.
• Start small, fair, and pragmatic to avoid unnecessary complexity, reduce compliance burden, and safeguard competitiveness. 
• A Single EU QR Code for all legal information requirements, ensuring simplicity, usability, and coherence across EU legislation.
• Protect trade secrets and sensitive technical documentation by ensuring that access is strictly limited, justified, and secured. Critical data must only be available on request. 
• Define DPP obligations only once the regulatory scope, governance model, access logic, and technical architecture are sufficiently specified. Introduce any new obligations through a phased approach, including pilot phases and a realistic transition period