ETRMA response to the public consultation on the Digital Product Passport (DPP)
The European Tyre and Rubber Manufacturers' Association (ETRMA) has submitted its views to the European Commission's public consultation on the digital product passport (DPP) and the requirements for service providers.
The tyre industry will issue DPPs for the tyres they place on the European market. In 2022, they created a data space, the Global Data Service Organisation for Tyres and Automotive Components (GDSO), to whom ETRMA is associated, to allow tyre lifecycle events traceability and data exchange across the tyre circular economy. GDSO could play the role of DPP SP for the tyre industry. In this context, we recommend:
ETRMA supports the Commission's efforts to create a harmonised, fair, and secure framework for DPP service providers, recommending to:
- Consider existing initiatives like the tyre industry data space, GDSO, in the definition of DPP SP roles, as well as Data Governance Act requirements for trustable data intermediation services,
- Require self-conformity assessment to CEN/CENELEC DPP standards for the management of DPP by DPP SP,
- Require ex-ante cybersecurity certification of DPP SP to manage the business sensitivity of DPP backup copies at the right level, especially for serialised product identification,
- Guarantee a fair, transparent and affordable financing mechanism of DPP services that is inclusive and future-proof over the products lifetime,
Provide a clear roadmap with sufficient time for implementation to cope with the complexity of the system and the number of remaining open questions
Read more in our response below.
