EUROBAT feedback on the Draft Implementing Regulation on Digital Product Passport Registry.

EUROBAT notes that the draft Commission Implementing Regulation goes well beyond the concept of a simple identifier repository and instead establishes the digital product passport registry as a central compliance gateway, including functions for verifying data completeness, validating operator identity and issuing proof of registration. This materially expands the operational scope of the registry and creates significant legal and practical uncertainty for economic operators, particularly in relation to the expected architecture of the registry, its data model and the division of responsibilities between the Commission, economic operators and downstream value-chain actors.

The main points of concern for EUROBAT are:

• The registry appears broader than a simple identifier repository.
• The semantic repository may define battery passport data models.
• The scope of “data completeness” remains unclear.
• The implementation timeline and pilot phase are not yet defined.
• Customs handling of imported batteries needs alignment.
• The scope of data updates in the registry is vague.
• Access rights for downstream actors require a workable mechanism.
• The 10-year retention period may be too rigid for some batteries.

Read the full response here.