Strengthening Trust in Data for Security and Trade – Linking PNR Evaluation and EUTIR Development

September 2025

The document provides strategic feedback to the European Commission on strengthening trust in data for security and trade, linking the evaluation of the Passenger Name Record (PNR) Directive with the proposed European Trade Indexes Registry (EUTIR). It highlights the PNR system’s role in combating terrorism and serious crime while respecting fundamental rights, and draws parallels with the need for a secure, interoperable digital trade infrastructure. The EUTIR is presented as a decentralised, EU-level trust anchor designed to ensure authenticity, traceability, and verification of trade-related data across platforms such as eFTI, Digital Product Passport (DPP), CBAM, and EU Customs systems. The proposal emphasizes integration with global identifiers like LEI/vLEI, alignment with EBSI and DLT technologies, and harmonisation across Competent Authorities, Service Providers, and Economic Operators. The document calls for legislative enhancements to establish EUTIR as a cornerstone of the EU’s digital, green, and competitive future.