Digital Product Passports: BASA Calls for a Practical, Harmonised Approach

BASA, the Adhesives & Sealants Association for the UK and Ireland, supports the ambition behind Digital Product Passports (DPPs) as a way to improve transparency, sustainability and communication across supply chains. However, BASA is increasingly concerned that, without careful coordination and clear principles, current policy development in both the EU and UK risks making DPPs fragmented, burdensome and counterproductive to their original objectives.

1. Key BASA Concerns

1.1 Risk of Fragmentation Across Sectors

Current developments indicate that DPPs are being pursued through multiple legislative pathways (e.g. Ecodesign for Sustainable Products Regulation (ESPR), Construction Products Regulation (CPR), batteries legislation and consumer legislation), raising the risk of diverging rules and duplicated systems:

• The European Commission has already initiated work on a construction-specific DPP system under the CPR.
• At the same time, horizontal DPP frameworks are being developed under ESPR and other legislation.
• The UK is pursuing its own DPP plans for both construction and consumer products.

This creates a real risk that:

• Construction products, consumer goods and other sectors develop separate DPP architectures.
• Economic operators must comply with multiple, incompatible systems.

BASA strongly supports the principle that horizontal elements must be harmonised across legislation to ensure interoperability and reduce administrative burden.

1.2 Risk of UK–EU Divergence

With parallel regulatory development in the UK and EU, there is a growing risk that:

• UK DPP requirements evolve separately from EU frameworks.
• Companies operating across both markets face dual compliance systems.

BASA urges both UK and EU policymakers to:

• Align on core architecture, data standards and governance principles.
• Avoid creating non-tariff barriers to trade.

1.3 DPP Scope: Value Chain Tool – Not an Enforcement Tool

BASA strongly emphasises that DPPs must remain a tool for value chain communication, not a mechanism for enforcement. FEICA, the European Adhesives & Sealants Association, has clearly stated that DPP content should be limited to information relevant to value chain communication and should not be used for enforcement purposes. Authorities should request additional information directly from companies where necessary.

BASA is concerned that current discussions risk:

• Expanding DPP use into market surveillance and regulatory enforcement.
• Creating legal uncertainty around data use.
• Discouraging full and open data sharing within value chains.

1.4 Data Minimisation and Proportionality

DPPs must follow a clear principle: “As much data as necessary, but as little as possible.”

Excessive or unclear data requirements will:

• Increase administrative burden, especially for SMEs.
• Introduce legal risks around data accuracy and liability.
• Delay implementation.

Both FEICA and the Digital Consumer Information Alliance (DCIA) stress the need for:

• Proportionate, phased introduction of requirements.
• Data requirements based on technical feasibility and supply chain maturity.

1.5 Lack of Harmonised Digital Labelling Framework

The absence of a consistent overarching framework for digital product information is a major concern.

DCIA highlights that:

• Fragmented rules across legislation and EU Member States create barriers to adoption and innovation.
• There is a need for:
  • “One product, one data carrier”
  • A harmonised approach to digital labelling.

Without this, DPPs risk becoming:

• One of several overlapping digital tools.
• Confusing for users and inefficient for industry.

1.6 Critical Operational Concern: DPP Register Requirement

BASA is particularly concerned about proposals requiring mandatory registration of a DPP before a product can be placed on the market.

This raises serious risks:

• Market access dependency on IT infrastructure.
• Potential single point of failure.
• No clear contingency planning for:
  • System outages.
  • Cyber incidents.
  • Data access failures.

Without robust safeguards, this could:

• Disrupt supply chains.
• Prevent compliant products from being placed on the market.
• Create disproportionate business risk.

2. BASA Policy Recommendations

BASA calls on UK and EU regulators to adopt the following principles:

2.1 Ensure Full Harmonisation

• Establish a single horizontal DPP framework applicable across sectors.
• Prevent additional national or sector-specific deviations.
• Promote common data standards and interoperability.

2.2 Align UK and EU Approaches

• Maintain regulatory coherence across jurisdictions.
• Use international standards where possible.
• Avoid duplication of compliance systems.

2.3 Clearly Define Purpose of DPPs

• Limit DPPs to value chain communication.
• Explicitly prohibit use as a primary enforcement tool.
• Ensure clear rules on data access and use.

2.4 Apply Data Minimisation and Proportionality

• Restrict data to what is necessary, relevant and feasible.
• Introduce requirements gradually and based on evidence.
• Avoid “nice-to-have” data obligations.

2.5 Develop a Coherent Digital Labelling Framework

• Adopt the “one product, one data carrier” principle.
• Integrate DPPs into a broader, consistent digital information system.
• Support language-neutral, user-friendly digital solutions.

2.6 Safeguard Operational Resilience

• Avoid making market access conditional on real-time system availability.
• Introduce fallback mechanisms and contingency planning.
• Ensure systems are:
  • Robust.
  • Secure.
  • Scalable.

3. Conclusion

BASA supports the ambition behind Digital Product Passports but stresses that successful implementation depends on getting the fundamentals right.

Without harmonisation, proportionality and clarity of purpose, DPPs risk:

• Fragmenting the Single Market.
• Imposing unnecessary burdens on industry.
• Undermining their own objectives.

BASA stands ready to work with policymakers to ensure that DPPs are:

• Practical.
• Harmonised.
• Fit-for-purpose.
• Supportive of innovation and competitiveness.

• ---

  BASA members can access this information as a position paper (PP100) by logging in to the members only Info Hub here. Work for a member company but don't have our own login? This is a membership benefit, so please contact the office to request access.