Feedback on the Future of Response to the Call for Evidence on Regulation (EU) 2019/1148 and Strategic Input on Securing the Digital Single Market

The document is a policy input from the DigitalTrade4.EU consortium to the European Commission, responding to the review of Regulation (EU) 2019/1148 on explosives precursors. It argues that the current list-based control system is outdated and easily circumvented, and proposes a digital-first approach centered on Digital Product Passports (DPPs) for high-risk chemicals. The DPP would provide end-to-end, tamper-proof traceability of chemical products using secure, machine-readable data (e.g., via blockchain), enabling real-time monitoring and automated anomaly detection. The proposal aligns with broader EU goals for a seamless, secure Digital Single Market, leveraging global standards like UNCITRAL MLETR, eIDAS 2.0, and UNECE Recommendation No. 49 to ensure interoperability and reduce administrative burdens—especially for SMEs. The consortium recommends launching a pilot project, championing global digital standards, and collaborating on implementation to transform supply chain security into a catalyst for digital innovation and EU strategic autonomy.