EUREFAS answer to consultation on Digital Product Passport Registry

EUREFAS broadly welcomes this draft Implementing Regulation as a necessary and well-structured step towards operationalising the Digital Product Passport framework. The registry architecture, the tiered access system, and the inclusion of value chain actors as legitimate DPP updaters reflect a sound understanding of how products circulate across the economy. We offer the following targeted recommendations to ensure the framework works effectively for the refurbishment and repair sector.

1. A welcome step: recognising value chain actors as DPP updaters

EUREFAS welcomes the Commission's decision to include independent refurbishers and repairers among the actors entitled to update existing Digital Product Passports. This is a necessary and meaningful recognition of the role our sector plays in extending product lifetimes. Ensuring that refurbishment operations are traceable and reflected in the DPP will strengthen consumer trust and market transparency. To that end, semantic data fields linked to repair and refurbishment should already be included to ensure that those activities are covered from the outset.

2. Verification must be lightweight and SME-friendly

While EUREFAS supports the principle of verified access to the registry, we urge the Commission to ensure that the verification process for value chain actors - including refurbishers and repairers - is at low cost, simple, and proportionate. A prominent part of the refurbishment is composed of SMEs operating with limited administrative resources and thin margins. A burdensome verification process involving qualified electronic seals, complex identity checks or recurring costs every three years risks excluding small operators from the registry, undermining the very circular economy objectives the DPP is designed to serve.

3. Simplified DPP creation for imported second-hand products

Under the current framework, refurbishers placing imported second-hand products on the EU market without an existing DPP would be required to create one from scratch — despite not being the original manufacturer and having no access to the underlying technical data.

This is both technically unrealistic and disproportionate. Refurbishers do not have access to material composition data, engineering specifications or test results that typically underpin a DPP.

EUREFAS urges the Commission to introduce a simplified DPP creation pathway for second-hand imported products, allowing refurbishers to generate a DPP by reference to an existing EU DPP of an identical or equivalent model. This approach would preserve the integrity of the registry while acknowledging the structural information asymmetry faced by refurbishers.

4. The 10-year data retention period is incompatible with circularity objectives

The proposed 10-year default data retention period is insufficient in the context of a circular economy. Many electronic products - laptops, gaming consoles, smartphones - can have a useful lifespan well beyond 10 years, particularly when refurbished. Deleting DPP data after 10 years would effectively cut off access to critical product information precisely when it is most needed: when a product re-enters the market for a second or third life.

EUREFAS recommends:

• A minimum 15-year retention period for technology and electronics products.
• A derogation from the DPP creation obligation for older second-hand products where the original DPP data is no longer available, to avoid penalising refurbishers for data that was never in their possession.