The harmonizing effect of "digital product"

I harbor a hope–and a hypothesis–that the term "digital product" can be a harmonizing and unifying force for good across regulatory terms and can provide clarity in how to better regulate digital products.

Here's an example: I recently came upon this definition in EU Directive 2015/1535 for service--which relies on another term "information society service" (ISS):

(b) Service: Any Information Society service — that is, any service normally provided for remuneration, at a distance, by electronic means and at the individual request of a recipient of services. The sub-definitions are:
"At a distance" — the service is provided without the parties being simultaneously present.
"By electronic means" — the service is sent and received via electronic equipment for processing (including digital compression) and storage of data, and entirely transmitted by wire, radio, optical, or other electromagnetic means.
"At the individual request of a recipient of services" — the service is provided through the transmission of data on individual request.

I'm somewhat delighted in the symmetry that, like my proposal for digital product, the definition provides three criteria for an "information society service": (1) at a distance, without both parties being present, (2) by electronic means, and (3) at the individual request of a recipient, which appears to require some voluntariness to the use of an ISS. (To distinguish from surveillance services? Unclear.)

How does this definition map to my proposed definition of digital product?

1. "at a distance" -> relies on all three capabilities of digital products: software-driven allows the manufacturer to be absent, as does connectivity and the user interface, which behaves as a proxy for the manufacturer.
2. "by electronic means" -> that's also obviously reliant on all three qualities of digital products.
3. "at the individual request" -> Seems like this is trying to indicate that if an individual opens a website or app, they have made a request. Perhaps, but if this is trying to be a stand-in for consent, it's doing a poor job of it (which is saying something given the flaws of consent). Moreover, I suggest that virtually every digital product fails to meet this last criteria, since consumers aren't requesting (or even knowledgeable of) all the behaviors of the service, specifically the commercial surveillance baked into most products.

I hadn't seen the definition of an ISS before this week and I'm struck at its valiant effort at making this definition in 2015.

I also started to map terms like "product" and "service" across key EU regulations and directives. TLDR: they don't match. (I'm moving this into a Baserow file to share for the curious.)

Could digital product be a constructive evolution of some of this older language in EU law?