Everything You Need to Know About the EU Digital Product Passport

As forecasted in our 2023 recap, the introduction of the EU Digital Product Passport (DPP) is about to change how we think about transparency and sustainability in product manufacturing and retail. It will not only present EU economic actors with a unique set of opportunities and challenges, but should also create a new precedent for global market practices in the coming years.

Deepening our analysis of this key piece of legislation, after discussing the ESPR’s requirements on ecodesign and the destruction of unsold goods, it’s time to explore the highly anticipated Digital Product Passport. So, get ready to dive into the facts behind the DPP, the profound impact it promises for businesses, consumers, and the broader EU ecosystem.

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What is the Digital Product Passport?

Established under the Ecodesign for Sustainable Products Regulation (ESPR), the DPP is a concept of a digital information tool designed to provide comprehensive information regarding the environmental and sustainability attributes of products commercialised in the EU market.

Similarly to the EU’s Extended Producer Responsibility (EPR) schemes, DPP will foster better environmental practices across value chains that go beyond the block’s borders, and achieve the following objectives:

• Informing value chain actors (e.g., sorters, recyclers) about product’s sustainability and circularity parameters, as well as products’ composition – all this with the goal to facilitate the product’s disassembly, reuse, or remanufacturing possibilities accelerating the shift towards a circular economy.
• Empowering consumers to make informed buying choices by informing them about products’ sustainability.
• Enabling market surveillance authorities an effective scan of products available on the EU market assessing their compliance with the EU product ecodesign requirements.
• Creating new business opportunities through circular value retention and optimisation, leveraging improved data access for activities like product-as-a-service, repair, servicing, remanufacturing, and recycling.

The DPP will also complement the EU Green Claims Regulation, serving as a practical tool against greenwashing, and is certainly an instrumental initiative in making the European Green Deal a reality.

The Scope and Implementation Timeline of the DPP

The DPP will be compulsory for a broad range of product categories to be defined by delegated acts adopted by the EU Commission. According to the agreement reached last December on the ESPR proposal, initial priority product groups will include:

• Iron, steel and aluminium
• Textiles, notably garments and footwear
• Furniture, including mattresses
• Tyres
• Detergents
• Paints
• Lubricants
• Chemicals
• Energy related products
• ICT products and other electronics

The adoption of a DPP does not exclude the need to comply with other information requirements already established for certain sectors, such as the ones created by the EU Textile Labelling Regulation, as part of the EU Textile Strategy.

Expected Timeline

The specifics about what kind of information must be included in the DPP will be determined by the EU Commission via delegated acts expected to be finalised by Q4 2025. The first Digital Product Passports are set to become operational by 2027/8, focusing on high-impact categories like batteries for electric vehicles, textiles, and furniture. However, proactive adoption by European brands is expected as early as 2025.

DPP Information Requirements

The DPP will make sustainability information available to stakeholders across the entire value chain. Based on the ESPR proposal, companies should expect to have to disclose information on the following product parameters:

• Durability
• Recyclability
• Recycled content
• Chemical substances of concern present in the product
• Product’s traceability information (e.g., production facilities along the value chain)

The methods for the calculation of the above product parameters, traceability requirements, as well the scope substances of concern, will be established in the ESPR delegated acts (to be finalised in Q4 2025).

Digital Product Passports: Key Design Elements and Data Requirements

In order to comply with the standards of the new regulation, organisations should have the following technical criteria in mind:

• Product passports will focus on uniquely identifying and connecting products or their components;
• Information for the product passports will be stored locally by economic operators. There will be no central registry containing information on all products.
• Data access will be granted on a strict “need-to-know” basis, meaning that some data will be public, while other data will have restricted access;
• All technical standards will be open and applicable on a global scale.

The technical standards for the development and deployment of the DPP are still being developed by the European Commission and the European standardisation bodies. They will be published together with the information requirements in the ESPR delegated acts.

Getting EU Businesses Ready for the DPP

The introduction of the DPP presents both opportunities and challenges for EU economic actors. On one hand, organisations can leverage the DPP to innovate and differentiate themselves, enhancing brand trust and attracting an ever growing environmentally conscious consumer base.

On the other hand, businesses must find their own way through the complexities of international value chain monitoring, data collection and management, and several other requirements for compliance.

To effectively adapt to the upcoming changes, European brands should start by familiarising themselves with the DPP requirements and assessing their current product portfolios against them. Investing in digital infrastructure will also be essential for many players, as well as working with supply chain partners to develop new sustainability practices and ensure coherence and transparency.

To capitalise on the opportunities presented by the DPP, businesses should also consider partnering with public affairs experts, such as those in the Ohana team, who have the network and the knowledge to navigate the Brussels landscape. By engaging with policymakers and participating in the development of the new standards and frameworks, your organisation will be in a position to lead the change instead of simply following it.

Want someone with deep experience and connections in the EU to help guide your sustainability strategy? Get in touch!

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