Minimum Evidentiary Properties for Information Requirements under the Ecodesign for Sustainable Products Regulation: A Technology-Neutral Proposal

Regulation (EU) 2024/1781 (ESPR) requires that information requirements on substances of concern make it possible to track them throughout the life cycle of products (Article 7(5)), that the data in the digital product passport (DPP) be accurate, complete and up to date (Article 9(1)), and that data authentication, reliability and integrity be ensured (Article 11(g)). JRC methodological work specifies which information is to be provided and how its verification could be organised, and notes that verifying the completeness of information "is expected to be a challenge" (JRC143683, p. 158). The JRC's methodology for DPP data requirements (JRC145830) identifies verifiability, attributability and the retention of previous versions as principles for DPP data. This note proposes six minimum evidentiary properties that records of declarations and test results could satisfy so that competent authorities can check them: time-anchoring, attribution, correction lineage, independent verifiability, differentiated access and point-in-time extraction. The properties are technology-neutral, reuse information that economic operators already hold, and rest on provisions and JRC principles that already exist. The note distinguishes the integrity of a record from the correctness of its content, which only testing and inspection can establish, and states what the properties do not achieve.