The association argues that a rigid approach such as producing a DPP for each individual item may impose disproportionately high costs, especially in the textiles and apparel industry, where low-value items would be affected most.
The DPP, a requirement under the Ecodesign for Sustainable Products Regulation, will become mandatory for selected product groups in 2027, with all relevant categories expected to comply by 2030.
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The initiative aims to improve supply chain transparency by supplying detailed data on a product’s origin, composition, environmental impact, and recommended disposal.
However, Ecommerce Europe has raised concerns regarding the practical challenges of meeting item-level granularity for products such as shirts, given the industry’s complex supply chains and the difficulty of identifying a uniform ‘batch’ among large volumes of similar goods.
Although the regulation’s Article 10(1)(f) authorises DPP granularity at item, batch, or model level, Ecommerce Europe contends that these definitions do not always align with the structure of the apparel sector.
The association proposes flexible benchmarking for granularity, based on corporate value and cost considerations.
It has also recommended that any assessments used to justify granularity choices be made publicly available, provided they do not include commercially sensitive information, so as to maintain oversight by authorities.
In its position, Ecommerce Europe underscores that a successful DPP implementation depends on three central principles.
Firstly, it urges policymakers to account for existing business practices and the difficulties of gathering and sharing supply chain data. Many companies, the association notes, are investigating how best to integrate the DPP within their operating models and are encountering notable challenges in accessing and distributing relevant data across value chains.
Ecommerce Europe believes that “building on these initiatives will be crucial in encouraging uptake in the e-commerce sector,” and says incentivising stakeholder participation is necessary to prevent unnecessary costs and burdens.
A second principle advanced by the group is that the DPP should be easy to use and rolled out gradually. Given that many businesses expect sweeping changes to their operations, a phased introduction is viewed as key to minimising uncertainty and enabling measured investment.
The association advises that initial DPP mandates should require only basic, easy-to-digitise data points, with priority given to information that does not need frequent updates.
Finally, Ecommerce Europe recommends that any move to expand the DPP to new product categories should be carefully assessed, taking on board lessons learned from the introduction in the textile and apparel segments. The association calls on the European Commission to conduct comprehensive evaluations of the technical, practical, and cost implications to ensure ongoing user-friendliness.
Ecommerce Europe said it aims to support broad acceptance of the DPP concept across all types of e-commerce businesses and their customers, regardless of business model or role in the supply chain.
