Digital Product Passports: The key to sustainable products in the age of transparency

Who will need to prepare DPPs?

A growing number of EU regulations will mandate the preparation of DPPs, or elements of it, to make product-related information digitally available. To date, this includes the ESPR, the Batteries Regulation, and the upcoming revised Construction Products Regulation.

The ESPR requires DPPs for 13 initial product groups, including energy-related products, electronics, iron, steel, aluminium, textiles, furniture, mattresses, tyres, detergents, paints, lubricants, and chemicals. The scope of the ESPR will gradually be expanded to include more product groups in line with the EU’s decarbonisation and sustainability requirements.

Once adopted, the Batteries and Construction Products Regulation will most likely require DPPs for all products that fall under the regulations and sold on the European market.

Preparing DPPs will be a collective effort. The responsibility for preparing the products lies with manufacturers, importers, and other entities introducing regulated products to the EU market. This extends to suppliers, retailers, and other intermediaries who also need to prepare and pass on DPPs of components or assembled products.

To guide and harmonise the preparation of DPPs, the EU will publish Delegated Acts that lay out the requirements for the DPPs. Standardisation organisations will help streamline the process by developing harmonised standards, while notified bodies offer third-party certification under the Delegated Acts.

How do you prepare for a future with digital product passports?

The EU Commission will soon publish detailed Delegated Acts that specify the exact requirements for DPPs. In the meantime, it is advisable to start preparing based on the available requirements in the ESPR and the expected requirements of the Delegated Acts to stay ahead of the curve. Preparation should address the following steps of the DPP journey.

• Regulatory navigation

In the beginning, creating a DPP can be both complex and time-consuming. It requires regulatory navigation to identify the products, components, and materials required to have a DPP based on the different EU regulations. These must be analysed and structured to meet all regulatory requirements, potentially lacking guidance that companies need to navigate.

• DPP process design and data sourcing

Once the data requirements have been mapped, a structure of the end-use product and its nested intermediate products can be designed. Data must be sourced by mapping internal systems, reporting current product sustainability data, and documenting products such as EPDs and LCAs. Significant data gaps that need filling through supply chain engagement should be identified.

• DPP launch and implementation

To launch and implement DPPs, the product needs to be physically tagged and the DPP made available on the chosen digital platform, which meets requirements around interoperability, flexibility, and more. The access rights need to be set on a need-to-know basis, e.g., consumers and remanufacturers should be able to see the relevant information. Implementing DPPs involves not only upskilling teams and aligning internal processes but also developing efficient procurement practices to facilitate their smooth generation. DPPs should also be safeguarded by storing a backup with a certified third-party DPP service provider. Dealers and online marketplaces must have access to the data carrier or unique product identifier for the corresponding product.

Following the launch of the DPP, the data needs to be updated through the product’s lifecycle by relevant stakeholder(s).

Navigating the challenges and opportunities

As the expectation for DPPs to come into force by 2027 looms, now is the time for industries to start preparing. Companies should start exploring how DPPs can be integrated into their operational and strategic planning. By doing so, they will not only be prepared to comply with impending regulations but also position themselves at the forefront of the DPP agenda and capitalise on related strategic opportunities.