Building Sustainable Products Without Building a Surveillance Infrastructure

The European Pirate Party has submitted its response to the European Commission’s consultation on the Digital Product Passport Registry.

What is the Digital Product Passport Registry?

The EU Digital Product Passport is a central European database that acts as a secure hub and verification portal for product compliance data.

Rather than storing complete lifecycle data directly, the Registry acts as a decentralized index. It holds unique product identifiers linked to corresponding “digital twins” hosted by decentralized corporate servers or service providers. This setup allows EU customs authorities, market regulators, and consumers to immediately scan a physical data carrier (like a QR code or NFC chip) to query the central Registry and dynamically retrieve authenticated, up-to-date compliance and sustainability metrics.

Key Rollout Timeline

• July 19, 2026: The EU Digital Product Passport (DPP) rollout begins with the launch of the infrastructure. The central DPP Registry will serve as a prerequisite for compliance, with a focus on complex assets and industrial equipment.
• February 18, 2027: Mandatory digital passports roll out for large EV and industrial batteries.
• Late 2027 and Beyond: Other high-impact sectors, such as textiles, toys, construction materials, and electronics, will come under the mandate’s purview.

As a digital tool, the DPP registry will contain a product’s information throughout its lifecycle to enable and enhance its traceability and transparency of sustainability performance. The core idea is to ensure regulatory compliance. Providing impetus to the EU’s innovation drive while furnishing consumers with the requisite product knowledge to support sustainable choices are among the other motives behind the EU’s implementation of the Digital Product Passport Registry.

European Pirates support these goals and recognize the system’s potential to strengthen the circular economy.

However, the proposed Registry goes far beyond a simple product database. It introduces a centralized system for identity verification, logging, access management, and data governance that will affect businesses, public authorities, and potentially millions of users across Europe.

The European Pirates have submitted it’s response to the European Commission’s consultation call on the Digital Product Passport (DPP) Registry. Our response to the European Commission is based on our firm belief that Europe should not have to choose between environmental goals and basic freedoms.

In our submission, we highlight several concerns:

• Long-Term Logging and Monitoring Risks

The Registry would keep detailed logs of user activity for years. Without clear rules for protection, access, and deletion, these logs could become a means of monitoring behavior rather than ensuring accountability.

• Market Access Linked to Digital Identity Infrastructure

Joining the Registry primarily relies on eIDAS-based verification, which could make it harder for small businesses and non-EU participants to participate. Digital identity systems could end up acting as gatekeepers and creating barriers to free-market access.

• Lack of Transparency and Public Oversight

Even though the Registry is publicly funded, it gives the public few chances to review or question it. Citizens, researchers, and civil society groups should be able to access basic information and take part in decisions about how the system develops.

• Open Infrastructure and Accountability

The draft does not require open-source software, independent security audits, or transparent governance of the Registry’s semantic repository. Public digital infrastructure should remain auditable, interoperable, and free from unnecessary proprietary dependencies.

Our Recommendations

Supported by extensive research, keen observation, and technical analysis, European Pirates call on the Commission to strengthen data protection safeguards, limit unnecessary retention of personal data, introduce stronger procedural protections for affected operators, ensure meaningful transparency, and require open, independently auditable digital infrastructure.

The Digital Product Passport can help build a more sustainable economy. But sustainability and digital rights must go hand in hand, not at the expense of one another.

Click here to read and download our full consultation submission:

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