Digital Product Passport (DPP)
We are facing a huge transformation that will affect all of us, as companies in all roles, from raw material suppliers, chemical producers, component manufacturers, product manufacturers, second-hand users, repair companies, as well as citizens and as consumers. Our behaviour and lifestyles, the way products are produced and consumed are to be massively changed in order to be able to live in a more sustainable world in the future.
The first industrial revolution replaced manual labour with the steam engine. The second followed with the assembly line and mass production. The third was the digital revolution. And in the fourth, it is no longer that the people communicate with each other via the internet, but things will communicate with each other, we are talking about the complete digital transformation. Industry 4.0 means the integration of intelligent digital technologies into manufacturing and industrial processes. This includes a range of technologies, including industrial IoT networks, Artificial Intelligent, big data, robotics, and automation.
There will be digital twins for machines, things, objects and products that are networked with each other and can communicate independently, even concluding valid contractual transactions.
A very important tool in this regard is the Digital Product Passport.
Digital transformation
Some will already have a rough idea of what that could be. Maybe a QR code on the products and the packaging with a link to a website where information for different access holders can be accessed?
Something like this already exists, some companies have already introduced it internally, and the EU has also introduced the central database of energy-related products "EPREL" and the energy efficiency label with QR code for certain product categories. Here, manufacturers have to register their products and upload certain information, which can then be viewed by authorities in a private area and by end users in a public area. Consumers receive information on the energy efficiency of the products in order to be able to make sustainable purchasing decisions.
The Digital Product Passport is much more than that. The information requirements are far more comprehensive and all actors in the value chain provide information and receive information to ensure resource-saving and sustainable processes.
What it is … in short:
„The digital product passport is a data set that summarises all components, materials, and chemical substances, but also information on repairability, spare parts or proper disposal for a product. The data comes from all phases of the product life cycle and should be able to be used to optimize design, manufacture, use, recycling, re-use and disposal.“ [BMU (2020a)]
It is therefore an important factor in making products sustainable and for the digital transformation as well as for the transformation to a Circular Economy.
The European Green Deal defines also other measures such as the European Climate Law and the Circular Economy Action Plan, including a Sustainable Products Initiative (SPI), with a specially focusing on resource-intensive sectors such as textiles, construction, electronics and plastics. The same applies to other strategies such as Industry 4.0 or the sustainability strategy for chemicals. The Green Deal mentions also an „ electronic product passport “, as a suitable means of providing relevant product information on the origin, composition, repair and dismantling options of a product as well as on handling at the end of its service life.
The Circular Economy Action Plan will include further measures, including measures to encourage businesses to offer reusable, durable and repairable products and to enable consumers to choose such products. The action plan deals with the right to repairs and the issue of planned obsolescence of devices, especially electronic devices. It should be possible for consumers to make conscious choices and actively participate in the ecological transition.
The core task of the Sustainable Products Initiative (SPI) is the revision of the Ecodesign Directive. The Ecodesign Directive became the Ecodesign for Sustainable Products Regulation (ESPR), entered into force on 18 July 2024, it is the new framework for ecodesign. This regulation introduces the Digital Product Passport (DPP). The DPP provides comprehensive information on compliance and sustainability of products to authorities, supply chain ‘actors’ and consumers. That there is a benefit for all stakeholders, it is important that there is a standardised format for the information. The basis should be reliable, comparable and verifiable information. The specific details required for products under the ESPR will be outlined in delegated acts. The ESPR just sets out the framework for information requirements and the technical design of digital product passports. Depending on the product groups, there will be information requirements using digital product passports at model, batch or article level (i.e. for individual products, i.e. unit related).
A distinction must be made as to whether there are mere information requirements that can be queried via a data carrier, such as a QR code, via a website or whether digital product passports must also be provided on these websites, regardless of the model, batch or article (unit) level. Incidentally, the first delegated act adopted under the new eco-design regulation will not enter into force before 19 July 2025 (see ESPR, Article 4)
Registry
Article 13 of the ESPR introduces a product passport registry. It shall be set up until 19 July 2026 and maintained by the European Commission. The registry shall at least include a list of the data carriers and unique product identifiers to enable a connection to product passports. The registry stores information included in the products passport, the actual information that needs to be uploaded will be defined in additional legislation (‘delegated acts’) per product group.
Customs
Customs authorities will have access to the product passport registry via the “EU Single Window Environment for Customs” established in Regulation (EU) 2022/2399. The passport reference in the registry will be automatically validated. Without a valid reference the product cannot be released to the market.
Substances of concern
According to the Ecodesign for Sustainable Products Regulation (ESPR) information about ‘substances of concern’ shall be included in the product passport. The information comprises the name, the location and the concentration of the substances of concern and instructions for the safe use and disassembly of the product.
The substances of concern can be divided into three groups:
- Substances of Very High Concern (SVHC) with a concentration above 0,1% weight/weight;
- Substances classified as most hazardous according to CLP Regulation (EC) 1272/2008 or its successor (EU) 2024/2865;
- Substances that negatively affect the re-use and recycling of materials in the product.
Category C substances are not related to chemical safety or food safety. They are added to the information requirements primarily for sustainability reasons; it concerns substances present in products or used in their manufacturing processes which negatively affect products’ sustainability.
Batteries
Regulation (EU) 2023/1542 on (waste) batteries was published on 28 July 2023. The regulation introduces labelling and information requirements, among other things, on the battery's components and recycled content, an electronic "battery passport", and a QR code. To give member states and economic actors on the market enough time to prepare, requirements will apply with different deadlines.
This regulation has many aspects to be covered, which we are converting into requirements and functionality. It will also influence products that incorporate batteries. Information which are requested for the battery passport are:
• General battery and manufacturer information
• Compliance, labels, certifications
• Battery carbon footprint
• Supply chain due diligence
• Battery materials and composition
• Circularity and resource efficiency
• Performance
• Durability
A very important role in designing the technical implementation of the Battery Passport plays hereby the Battery Pass Consortium. This project is funded by the German Federal Ministry for Economic Affairs and Climate Action. The project contributes to the development of the EU battery passport as required by law in the EU Battery Regulation. The Battery Pass Consortium comprises eleven globally active consortium partners, from key industries, research institutions, academies, digital services providers in the field of open standards, battery analysis and tracking.
The CIRPASS Consortium plays an equally important role and is funded by the European Commission and aims to develop cross-sectoral DPPs for the three sectors of batteries, electronics and textiles. The project is scheduled to run for 18 months and involves 31 partners working on the project. These partners are representing thousands of industrial, research, digital, and international standards organisations across Europe and beyond.
The Battery Pass project complements the Circular Economy Initiative Germany (CEID) and cooperates with other partners such as the Global Battery Alliance (GBA), Catena-X and Gaia-X. The technical implementation is moving in the direction of the Digital Nameplate 4.0 as a submodel template of the Asset Administration Shell.
Both projects, CIRPASS and Battery Pass, play an essential role for the implementation of digital product passports in general. The two projects are in mutual exchange but have remained independent in terms of the recommendations and roadmaps.
Toys
The proposal for a new Toy Safety Regulation builds on the ESPR for the digital product passport. It defines the information requirements for toys to be mentioned in the DPP. It will come into effect 30 months after the finalisation of the Toy Safety Regulation. The DPP for toys shall contain the following information:
- Traceability; unique product identifier, name and address of the manufacturer, unique operator identifier, identification of toy, colour image, commodity code;
- References to all Union legislation and harmonised standards used;
- Notified body name and number, conformity assessment procedure, certificate reference (where applicable)
- The CE marking;
- List of allergenic fragrances that are present in the toy;
- Any substance of concern that is present in the toy.
- Safety information, warnings and instructions of use may be included in the product passport.
The product passport replaces the EU Declaration of Conformity (for toys).
Packaging
The highly anticipated Packaging (Waste) Regulation will introduce an EU Declaration of Conformity for packaging and further information requirements which shall be made available via a data carrier, such as a QR-Code.
Textiles
The EU Sustainable and Circular Textiles Strategy intends that textile products put on the market in the EU will have a long life, i.e. no more fast fashion, textile products shall be made from recycled fibres as much as possible, taking into account social rights and the environment. The measures include specific eco-design requirements for textiles to minimise overall CO2 emissions and environmental footprint. It also contains extended mandatory producer responsibility and more user-oriented information, and finally a Digital Product Passport as well as a Digital Product Label will be introduced. The revision process is ongoing, and the new regulatory text is expected to be published by the first quarter of 2025.
Construction Products and Buildings
Certain deficits of the actual CPR, including its inadequate contribution to the green transition, makes a new revision necessary. The proposal of a new Construction Products Regulation now contains targets to create a harmonised framework for assessing and communicate the environmental and climate performance of construction products. New product requirements will ensure that they are more durable, repairable, and recyclable and also easier to be recycled.
The proposal intends to establish an EU construction product register that is based as far as possible on the digital product passport. The proposal also expands the term "economic operator" in the case of "economic operators de-installing or dealing with used products for reuse or remanufacturing”.
Machinery
Last year, Regulation (EU) 2023/1230 on machinery was published. It does not mention a digital product passport for machinery. But future delegated acts under ESPR will introduce ecodesign and information requirements for certain types of machinery such as household appliances and motors.
Further product groups will follow. To be continued …
