Common Specifications: the EU's DPP Fallback Plan
A Digital Product Passport (DPP) needs shared technical rules so that data from different systems can be read and compared. Normally those rules come from harmonised standards, but standards take years to develop. Common specifications are the EU's fallback plan for when a standard is not ready in time.
Why shared rules are needed at all
A passport only works if its format is understood by the scanner in a shop, the system of a surveillance authority and a recycler alike. Without agreed rules, every manufacturer would describe a product its own way, and the data would be inconsistent and hard to process automatically.
That is why the ESPR (the Ecodesign for Sustainable Products Regulation, Regulation (EU) 2024/1781) relies on technical standards for identifiers, data carriers and the structure of the record. They make the passport interoperable, rather than just a nice-looking page. A shared technical language is the precondition for a passport that can actually be used across the value chain.
Harmonised standards and the presumption of conformity
EU law works through a mechanism known as the presumption of conformity. If a manufacturer applies harmonised standards published in the Official Journal, it is presumed to meet the corresponding legal requirements. That greatly simplifies demonstrating compliance, because instead of proving everything from first principles, you can rely on a recognised standard.
For the horizontal DPP, a European family of standards (the EN 182xx series) is being developed by the CEN-CENELEC JTC 24 committee, covering identifiers and data carriers among other things. Treat it as the direction of standardisation work, not a closed list of duties — the individual documents are still being drafted and updated.
The timing problem: standards take years
Developing and publishing a European standard is a process that typically takes years. It involves experts, consultations and agreement across member states. That is good for quality and market acceptance but bad for the schedule when sector obligations start applying faster than the standards are ready.
A gap then appears: the law already requires a passport for a given product group, but the relevant standard does not yet exist or is incomplete. To keep the DPP rollout from stalling, and to avoid leaving companies without a reference point, the EU needs a bridging solution that works faster than the full standardisation process.
What common specifications are
Common specifications are a set of technical requirements that the European Commission can adopt on its own through an implementing act. They act as an emergency substitute for a harmonised standard when that standard is not ready, is delayed, or turns out to be insufficient for the regulation's purposes.
When common specifications are in force, applying them grants the same kind of presumption of conformity as a standard. This gives manufacturers a clear, binding reference point even before the final standard appears. From a company's perspective the practical effect is therefore identical: you know how to build a compliant passport.
The link to regulatory simplification
The common-specifications mechanism is often tied to a wider push to simplify EU law, familiar from Omnibus-style packages. The idea is that regulation should be usable in practice, and that the absence of a finished standard should not block the whole market or delay the passport's entry into force.
For your company the takeaway is simple: DPP technical rules can come from two sources — a standard or a common specification — and both are binding. It is worth tracking which one applies in your sector, because that is what defines how your passport should look at any given moment.
What it means in practice
Whichever source of rules applies in your case, the sensible strategy is the same:
- build your passport on structured, portable data, ready to export in different formats,
- do not wait for a "final" standard if a common specification already applies to your product,
- choose a platform that can adapt its export format to changing technical requirements.
A good DPP platform insulates you from this complexity: it updates the data format when the rules change, without you having to rebuild the whole process. We cover the role of the registry in DPP registry vs EPREL, and the life cycle of the data in DPP data versioning and retention.
Key takeaways
- Harmonised standards give a presumption of conformity but take years to develop.
- Common specifications are the EU's fallback: technical requirements adopted by the Commission through an implementing act.
- Applying them produces a similar legal effect to a standard.
- The mechanism connects to regulatory simplification so the DPP rollout does not stall.
- What matters for a company is data readiness, not which source the rule came from.
See how CyfroPass keeps your passport aligned with current technical requirements without writing code. Visit cyfropass.pl and start with your first product.