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EU Digital Product Passports: sustainable products

Digital product passports allow any party to access product information, considering a product’s full lifecycle. This increases transparency and traceability, stimulating sustainable design. Read this explanatory article of the digital product passport and tips on how you can prepare your company.

Digital product passport in short

What is the digital product passport

  • Digital Product Passport (DPP) is a unique product tag that allows any interested party to access product information. It considers a product’s full lifecycle, across the whole value chain. 
  • This increases transparency and traceability of products, thereby stimulating circularity and sustainable design.
  • The European Commission (EC) also plans to introduce similar regulations on imported products, coming from outside the EU.

When do digital product passports become obligatory

  • The European Commission aims to reach the final approval of the Ecodesign for Sustainable Products Regulation (ESPR) in 2024. This is the overarching regulation introducing the digital product passport.
  • The first product groups are expected to be covered by DPP regulation in 2026.

Why digital product passports

  • Allows companies to share information on their products across the entire value chain.
  • Allows companies to show the environmental impact their products have.
  • Makes product information traceable and accessible to relevant value chain actors.

Who must comply with the Ecodesign for Sustainable Product Regulation

  • There are eight priority industries appointed: electronics, batteries and vehicles, textiles, plastics, construction and buildings, furniture, and chemicals.
  • Packaging is not getting its own set of rules, but will be treated as a component of other products. 
  • Initially, the EC plans to implement the DPP for all company sizes.

EU Digital Product Passports

Digital Product Passport (DPPs) form part of the Ecodesign for Sustainable Products Regulation (ESPR). Digital product passports are unique product tags that allow any interested party to access the information about the product’s sustainability across the whole value chain. This can be a consumer, an importer, or a regulatory body. 

Digital product passports will improve the transparency of products’ value chains. This makes it easier for relevant authorities to oversee and enforce adherence to the regulations. It also allows for consumers to make more informed choices about their purchases. 

Additionally, the EC anticipates that the ESPR will help avoid sustainability-related misinformation from producers and retailers. This is known as greenwashing. With its implementation, a company will have to substantiate any claims on the environmental performance of their product with supporting documents. 

What information must be included on the digital product passport?

The following information must be included on the digital product passport:

  • Information on sustainable performance
  • Traceability
  • Declaration of conformity
  • Technical documentation
  • User manuals
  • Information about the manufacturer, importer, or authorised representative.

The information would be stored in a registry set up by the Commission and accessible via a data carrier on the product, its packaging or documentation.

Ecodesign for Sustainable Products Regulation

On March 30th, 2022, the European Commission proposed a new regulation that aims to establish a general framework for ecodesign requirements of sustainable products. The proposed regulation replaces the existing rules that primarily focus on energy-related products. The goal of the new regulation is to make all products in the internal market more environmentally friendly by making them more durable, reusable, repairable, upgradable, and recyclable.

One key aspect of the regulation is the introduction of a digital product passport. This passport will contain information about the product's environmental impact, such as its carbon footprint and its potential for reuse and recycling. This information will help consumers make informed choices and encourage manufacturers to design products with sustainability in mind.

In addition to the digital product passport, the proposed regulation also includes rules for green public procurement. This means that public authorities will be encouraged to prioritie environmentally friendly products when making purchasing decisions. The regulation also aims to prevent the destruction of unsold goods by imposing a ban on this practice.

Overall, the proposed regulation is a step towards a more sustainable future. It introduces new rules that will help reduce the environmental impact of products, and encourages manufacturers to design products with sustainability in mind. The digital product passport is a particularly innovative aspect of the regulation that will provide consumers with the information they need to make more sustainable choices.

Summary of the Ecodesign for Sustainable Products Regulation.

The digital product passport is not the only aspect the ESPR will bring. Here is a summary of the changes that will occur as a result of the current proposal of the Ecodesign for Sustainable Products Regulation.

  • Scope: The regulation would apply to any physical good placed on the market, with a few exceptions such as food, feed, medicinal, and veterinary products.
  • Ecodesign requirements: Products on the internal market would have to comply with ecodesign requirements set out later in delegated acts for each group of products separately. Ecodesign requirements would aim to improve product durability, reliability, reusability, upgradability, reparability, possibility of maintenance and refurbishment, presence of substances of concern, energy use and energy efficiency, resource use or resource efficiency, recycled content, possibility of remanufacturing and recycling, possibility of recovery of materials, environmental impacts and expected generation of waste materials. The ecodesign requirements would be prepared by an expert group renamed as the Ecodesign Forum.
  • Performance and information requirements: The regulation distinguishes between performance requirements, such as durability and ease of repair, and information requirements. Information requirements should include at least requirements related to the product passport and to substances of concern. The required information would have to be provided on the product, packaging, passport, label, manual, or website.
  • Misleading labels: The Commission would be empowered to adopt rules on labels indicating the performance of a particular group of products, and the use of misleading labels that could mislead or confuse consumers would be banned.
  • Self-regulation measures: Two or more economic operators could submit a self-regulating measure establishing ecodesign requirements as an alternative to adoption of a delegated act, provided that their market share in terms of volume is at least 80% of the units placed on the market.
  • Destruction of unsold goods: Companies that discard unsold consumer products would be subject to transparency requirements and would have to disclose the information on a publicly accessible website. The Commission would be empowered to ban destruction of particular groups of products that have significant environmental impacts.
  • Incentives for sustainable products: Member States would be allowed to provide incentives for consumers to make sustainable choices, in particular when more sustainable products are not sufficiently affordable, by introducing eco-vouchers and green taxation.
  • Green public procurement: The Commission would be empowered to adopt delegated acts establishing ecodesign requirements applicable to public contracts, including mandatory technical specifications, selection criteria, award criteria, and contract performance clauses or targets.
  • Obligations of online marketplaces: Online marketplaces would be required to cooperate with market surveillance authorities, inform them of any action taken in cases of non-compliant products, establish a regular exchange of information on removed offers, and allow access to their interfaces. Member States would be required to empower their market surveillance authorities to order an online marketplace to remove non-compliant products.
  • Prevention of circumvention: Products that can detect if they are being tested in order to alter their performance and achieve a more favorable result would be prohibited.

Product sectors first in line in ESPR

The initial focus of the digital product passport is on the product sectors consumer electronics, batteries, and textiles. For most of these sectors, there already exist environmental regulation frameworks. The ESPR is planned to work in tandem with the current relevant legislation.

The EC aims at implementing the digital product passport across companies of all sizes. From large corporations to SMEs, from B2B to B2C companies. This creates clear expectations and full transparency for all supply chain actors. However, it could put extra pressure on SMEs and might slow down implementation. An alternative the EC is considering is applying DPPs to large corporations first, followed by SMEs in a later stage.  

Early action for your digital product passport

To prepare for the upcoming Digital Product Passport, companies can take several proactive steps.

  • First and foremost, they can start gathering and organising information about their products, including details on their composition, energy efficiency, and especially on environmental impact. These insights are eventually the content of your digital product passport. This process requires close collaboration between different teams within the company, including product design, engineering, and sustainability. It can be beneficial to find support from LCA consultants.
  • Companies can start exploring different digital platforms and technologies that can help them manage their Digital Product Passports. They can leverage tools such as blockchain and Internet of Things (IoT) sensors to ensure the accuracy and transparency of their data. Additionally, they can work with industry associations and standard-setting organisations to ensure that their product information is consistent and compatible with upcoming regulatory requirements.
  • Another critical step is to engage with customers and other stakeholders to understand their expectations and priorities regarding sustainability and transparency. This can help companies tailor their product information and communication strategies accordingly. They can also use this feedback to identify areas for improvement and innovation in their product offerings.
  • Finally, companies can invest in employee training and education to build internal expertise in digital product passports and related sustainability topics. This will help ensure that all team members have the knowledge and skills needed to create and manage digital product passports effectively.

By taking these proactive steps, companies can position themselves for success in a rapidly evolving regulatory and market landscape focused on sustainability and transparency.

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