In August, EBC submitted a reply to the European Commission’s consultation on the requirements for Digital Product Passport (DPP) service providers, under the Ecodesign for Sustainable Products Regulation (ESPR). This contribution reflects EBC’s ongoing commitment to ensuring that the DPP framework works for construction SMEs across Europe, as they will have to implement it under the Construction Products Regulation (CPR).
In its reply, EBC welcomed the Commission’s objectives of ensuring data integrity, security, and fair competition. Drawing on its involvement in the feasibility study for the CPR DPP system, EBC stressed that the DPP must be practical, accessible, and affordable for all economic actors, regardless of size.
EBC called for proportionate certification rules, favouring a hybrid model that combines self-declaration with third-party verification, where justified by risk. It underlined the importance of allowing SME organisations to act as service providers under fair conditions, and of providing legal clarity on the roles and responsibilities of all actors. It also emphasised that manufacturers, including SMEs, must retain ownership and control of their data, with storage and backup solutions located in territories offering strong legal protections in line with EU law. It urged the adoption of interoperable, user-friendly, and cost-effective technical solutions that integrate smoothly with existing SME systems.
EBC further highlighted the need for practical onboarding tools, standard templates for low-risk products, and targeted support to help SMEs with limited digital capacity. It warned against measures that could restrict the diversity of service providers or lead to market concentration, calling instead for balanced approaches that safeguard both competition and accessibility.
EBC will continue to engage with EU policymakers throughout the delegated act process to ensure that the DPP framework is ambitious, coherent, and grounded in the realities of SMEs in the construction sector.
To read the EBC Reply to the consultation, click here.
