1. Definitions
Provider: Łukasz Głuch, operating under the DPPera brand. Customer: an economic operator within the meaning of Article 2(46) of Regulation (EU) 2024/1781 (ESPR) or another business using the service. Passport: a digital product passport, a set of product data published under a permanent URL together with a QR code. Publication: fixing the passport content and assigning a permanent address; after publication the identifiers (GTIN, variant, batch, serial) are immutable. UPI: the unique passport identifier the customer submits to the DPP Registry. Active passport: published and not withdrawn. DPP Registry: the European Commission registry under Implementing Regulation (EU) 2026/1778.
2. Scope of the service
The provider hosts and maintains passports: a panel to create and edit, publication under a permanent address, a QR code, a dealer pack (Article 10(3)(b) ESPR), scan analytics and a backup of passport data. A published passport and its documents are stored in two independent systems at publication; each publication additionally stores an immutable snapshot.
The provider does not register passports in the DPP Registry on the customer's behalf, because the registry interface offers no such path. The customer registers; the provider supplies a UPI that passes registry validation and an instruction. Drafts are not covered by the guarantees in points 4 and 5.
3. Plans and fees
Net prices, paid in advance per period. Fair use: in the Marka plan up to 10 publications per calendar month, above that the provider proposes a plan change. Exceeding the active passport limit requires a plan change: upgrades apply immediately, downgrades from the next billing period. Invoice payment at launch; online payment in the panel is in preparation.
4. Durability guarantee
Payment arrears, termination or expiry of the contract do not shorten this period. When you migrate to another provider we keep the redirects from the old addresses. If the delegated act for your category requires longer, the period from the act applies.
A published passport remains publicly available under its address: for products under a passport obligation at least for the period required by the applicable delegated act, and for voluntarily published passports at least 2 years from the date of publication (decision of 21 September 2026; until then the draft said 5 years). The guarantee covers passports published in a paid period. Arrears, termination or expiry do not shorten this period. The provider keeps redirects from paths under its domain also after the customer moves to another provider. The public passport page never shows billing messages.
5. Payment arrears
Freezing suspends creating and editing passports, the code generator and SVG/EPS export, scan analytics, API access and document uploads. Freezing does not suspend serving published passports, the machine-readable output, downloading uploaded documents or exporting your own data.
6. Export and migration
The customer may at any time, including during arrears, export the complete set of their data in a structured format (JSON, CSV, ZIP with documents). On migration to another provider the provider hands over identifiers and keeps redirects as per point 4.
7. Withdrawal and retirement of a passport
Non-payment is not a reason for withdrawal. A voluntary passport may be retired after the guarantee period only when, cumulatively: the product has been withdrawn from the market, no scans have been recorded for 24 months, and the customer was notified 90 days in advance and did not object. When a customer permanently ceases business, the provider keeps the passports for the period in point 4.
8. Customer obligations
The customer is responsible for the truth, completeness and legality of the passport data and for the rights to the content and marks used. Registration in the DPP Registry and relations with authorities remain the customer's obligation as an economic operator (Article 8 of Regulation 2026/1778); using the service does not transfer that responsibility. The customer keeps billing and contact details up to date.
9. Liability
The provider is not liable for the consequences of regulatory decisions (changes to delegated acts or registry requirements) or for content entered by the customer.
10. Personal data
Personal data of panel users is processed in line with the privacy policy. For data entrusted by the customer the parties conclude a data processing agreement, drafted by a lawyer.
11. Changes and legal succession
Changes to the terms with 30 days' notice; price changes do not apply retroactively to paid periods; the guarantee in point 4 for already published passports cannot be shortened. The provider may transfer all rights and obligations to a legal successor, in particular a company formed by converting the business; the guarantees remain binding on the successor.
12. Final provisions
This version of the terms is a substantive draft. Until the final version is published, the terms of cooperation are confirmed in writing with each order.