Frankfurt, May 2026 – EuroWindoor has submitted a detailed feedback statement highlighting fundamental shortcomings of the European Commission’s draft Implementing Regulation on the Digital Product Passport (DPP) Registry pursuant to Article 13(5) of the Ecodesign for Sustainable Products Regulation (ESPR).
“We support the Digital Product Passport as an instrument for transparency and circular construction,” said Frank Koos, Secretary General of EuroWindoor. “However, the current draft has been designed without sufficient regard for the realities of an industry that consists almost exclusively of small and medium-sized enterprises. A comprehensive revision is essential before adoption.”
The draft Regulation applies directly to construction products via Article 76 of the Construction Products Regulation (EU) 2024/3110. Window and door manufacturers, the vast majority of them SMEs with fewer than 10 employees, will be required to register DPPs in the ESPR-based registry despite having no prior experience with the digital infrastructure it demands.
In its seven-point feedback, EuroWindoor identifies key areas requiring revision and proposes concrete amendments:
- Simplified verification: The eIDAS-based verification process imposes disproportionate costs (~€300–800/year) and complexity. EuroWindoor proposes access via national business registers.
- Proportionate IT security: Undefined security obligations create legal uncertainty. The Commission should offer a centrally managed secure access solution.
- User-friendly data entry: Free, guided tools must be provided. Data already submitted via the Declaration of Performance and Conformity (DoPC) must be referenceable without re-entry.
- Practicable registration levels: Item-level registration is unworkable for made-to-order products with millions of parametric variants. Registration at model-family or product-type level must be permitted.
- Account continuity: Rules for personnel changes, mergers and insolvency are missing. The 90-day proof-of-registration limit is inadequate for products with 30+ year service lives.
- Multilingual helpdesk: EU-wide implementation requires support in all official languages and national first-line support through industry associations.
- Circular economy enablement: Data retention must support at least 25 years as required by the CPR. Liability boundaries in reuse scenarios and duplication between DPP and DoPC data must be addressed.
EuroWindoor urges the Commission to integrate the principle of proportionality into the operative provisions and to ensure that no registration obligations arise before harmonised standards define the data scope. The association remains available for constructive dialogue.
For more see EuroWindoor Feedback on draft implementing act on Digital Product Passport Registry (May 2026).
Press Contact:
Miriam Weppler
EuroWindoor General Secretariat
Walter-Kolb-Str. 1-7
60594 Frankfurt / Germany
Phone: +49 (69) 95 50 54 – 36
Fax: +49 (69) 95 50 54 – 11
Email: GS@EuroWindoor.eu