LIA Submission on EU Digital Product Passports

This submission reflects input from 19 UK lighting manufacturers and suppliers, spanning SMEs through to large businesses, many of whom place products on the EU market and will therefore be directly impacted by forthcoming requirements.

We would like to extend our sincere thanks to all members who contributed to this work. Your insights have been critical in ensuring that the UK lighting sector’s voice is clearly and credibly represented at a pivotal stage in policy development.

A shared ambition - tempered by practical concerns

Across responses, there is clear recognition of the policy intent behind Digital Product Passports, particularly in supporting:

• greater transparency
• improved sustainability outcomes
• enhanced circularity across product lifecycles

However, this broad support is accompanied by consistent and important concerns around readiness, proportionality and implementation.

For many businesses (particularly SMEs) DPPs remain an emerging and largely unfamiliar concept, with limited prior experience of voluntary product passport systems. This highlights a clear need for early engagement and practical support ahead of any mandatory rollout.

Key messages from UK lighting manufacturers

1. Proportionality is critical

A central principle emerging from member feedback is the need for proportionate implementation.

Concerns include:

• The cost and administrative burden of compliance
• The potential for disproportionate requirements at unit or SKU level
• The risk that early over-prescriptive rules could impact competitiveness

There is strong support for a phased approach, starting with minimum or intermediate requirements and allowing time for systems and processes to adapt.

2. Data and system interoperability must come first

Members emphasised that the success of DPPs will depend on practical, aligned system design.

Priority areas include:

• Harmonised European data standards
• Interoperability with existing systems (e.g. ERP and PLM)
• Avoiding duplication with existing regulatory requirements

Without this alignment, there is a clear risk of fragmentation, inefficiency and unnecessary cost.

3. Managing complexity across large product portfolios

Survey responses highlight the scale of the challenge for lighting manufacturers:

• The majority of respondents manage large product portfolios, often exceeding 200 models
• Many companies expect several hours of work per product to collect and organise the required data for a passport

This underlines the importance of streamlined processes, standardised templates and realistic timelines, particularly for companies managing high product volumes.

4. Confidentiality and governance must be robust

Members also raised concerns around data governance, including:

• Protecting confidential business information
• Clarifying access controls and responsibilities
• Ensuring confidence in service providers and system governance

Flexibility in certification models (particularly in early stages) was seen as important to avoid unnecessary barriers to entry.

5. Support and transition will determine success

A consistent theme across responses is that successful implementation will depend as much on support as on regulation.

Members are calling for:

• Clear, sector-specific guidance
• Simplified tools and templates
• Training and awareness programmes
• Sufficient transition periods, including for legacy products

There is limited appetite for an enforcement-led approach without parallel support mechanisms.

A UK perspective in a European framework

While DPPs are being developed as part of EU regulation, their impact will extend well beyond EU-based manufacturers.

Many UK lighting businesses continue to place products on the EU market and will therefore need to comply with future requirements. Early engagement through this submission is essential to ensure that emerging frameworks are practical, proportionate and aligned with real-world operating conditions.

LIA priorities moving forward

Based on member feedback, The LIA’s key advocacy messages to the European Commission are clear:

• Proportionate, phased implementation is essential—particularly for SMEs
• Standardised, interoperable data systems must be prioritised
• Clear guidance, tools and transition periods are needed before enforcement
• Costs and administrative burden must not undermine competitiveness

Thank you to our members

This submission has been made possible through the time, expertise and openness of our members.

Your contributions ensure that policy discussions are grounded in practical industry realities, helping to shape outcomes that are both ambitious and workable for the lighting sector.

We will continue to keep members informed as policy develops and welcome further engagement as we support the transition towards Digital Product Passports.

As with previous regulatory transitions, early collaboration between industry and policymakers will be key to ensuring that Digital Product Passports deliver their intended benefits without unintended burden.