A position on Digital Product Passport rules for European service providers

09/12/2025 | Print view

EuroWindoor-Logo mit fünf gelben Sternen über dem weißen Text auf blauem Hintergrund. - © EuroWindoor — © EuroWindoor

EuroWindoor has submitted an opinion to the European Commission’s public consultation on the delegated act defining the rules for service providers involved in the Digital Product Passport (DPP) with relevance to construction products.

The current proposal sets out requirements for service providers on data security, availability, financial stability and potential certification. Recognising the impact on the window, door and facade sector, EuroWindoor supports greater transparency but calls for a balanced approach that avoids placing undue burdens on SMEs.

Eurowindoor’s key positions:

Data availability: A 99% uptime requirement is considered feasible, as high availability is needed not to stop manufacturing when DPP needs to be uploaded.

Confidentiality: EuroWindoor underlined the importance of protecting sensitive data, such as anti-violence features or project-specific product performance, which should only be accessed with verified interest.

IT realities: The window sector is largely composed of SMEs relying on specialised software providers. Manual data handling is unrealistic given the scale of implementation—around 76 million DPPs are expected annually for windows under the new CPR.

Certification: EuroWindoor advocates for a voluntary certification scheme. While some companies may benefit from certified service providers, especially regarding IT security, mandatory certification could impose unnecessary costs.

Flexibility: Manufacturers or groups of manufacturers should be allowed to act as their own DPP service providers to ensure efficiency and cost-effectiveness.

EuroWindoor remains committed to contributing to EU policy initiatives and calls on the Commission to ensure that the delegated act supports digitalisation without overburdening economic operators.

For more information you can find the full EuroWindoor position here.