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The FTAO's feedback on the European Commission’s draft Implementing Regulation establishing the Digital Product Passport (DPP) registry

The FTAO's feedback on the European Commission’s draft Implementing Regulation establishing the Digital Product Passport (DPP) registry
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The Fair Trade Advocacy Office (FTAO) has submitted feedback on the European Commission’s draft Implementing Regulation establishing the Digital Product Passport (DPP) registry under the Ecodesign for Sustainable Products Regulation (ESPR), calling on the adoption of targeted amendments that ensure inclusive access, fair cost allocation and clear roles for public authorities.
27 May 2026

The Fair Trade Advocacy Office (FTAO) welcomes the Commission's initiative to establish the technical architecture for the Digital Product Passport (DPP) registry under Regulation (EU) 2024/1781 (ESPR). The registry will form the operational backbone through which product sustainability data flows across global supply chains. The core architecture of the draft regulation, covering operator verification, registration procedures, logging and security is sound, and the FTAO broadly supports its objectives.

Drawing on experience from complex, multi-tier supply chains such as textiles, the FTAO has identified key gaps that could limit inclusiveness, accessibility and fairness in practice. Our contribution to the European Commission's public consultation proposes targeted adjustments to address four categories of gaps in the draft regulation, focusing on safeguarding access for all relevant actors, ensuring workable verification systems for non-EU stakeholders, preventing disproportionate burdens on smaller suppliers and clarifying the role of public authorities in using DPP data. 

Read our full contribution here.

Get in touch:

For any questions or to know more about our work on textiles, please contact Alena Kahle at kahle@fairtrade-advocacy.org.


The Fair Trade Advocacy Office is a member of the European Commission's Ecodesign Forum, the main arena for consulting stakeholders on the development of rules under the Ecodesign for Sustainable Products Regulation (ESPR). This expert group gathers a wide range of stakeholders, including specialists appointed by Member States, as well as representatives from industry, civil society and academia.


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