Moving from paper-based to digital product documentation

DIGITALEUROPE welcomes the EU’s initiative to give manufacturers the option to provide product documentation digitally. This transition is essential to reduce regulatory burden, advance environmental objectives and align EU product legislation with the digital age.

At this stage, it is crucial not to conflate moving to paperless documentation with the implementation of the Digital Product Passport (DPP), as doing so may delay modernising EU product legislation and impede achievable savings in the near term.

Recommendations

• Provide legal certainty for digital formats by revising the Blue Guide and related guidance to explicitly allow digital documentation across all applicable legislation.
• Use an omnibus proposal to harmonise EU product legislation to ensure that all Member States accept digital documentation as a valid and preferred alternative to paper. This should cover declarations of conformity, instructions for use and other required technical documentation.
• Do not make implementation of the DPP a precondition for digital documentation. The move to digital documentation can and should proceed independently of the development of the more comprehensive DPP system and should be technology neutral.
• In cases where the DPP is mandated, allow it to include digital instructions and declarations of conformity, but do not extend DPP obligations to other product categories solely to facilitate the digital delivery of such documents.