Imagine every product in the market coming with a digital ID, such as a RfID or QR code that holds comprehensive information about that product's lifecycle, from its origin and material content to its manufacturing processes and eventual disposal or reuse. This is a DPP in a nutshell. DPPs serve as a repository of key lifecycle data that supports circular economy and energy-efficiency objectives by promoting transparency, enabling informed decision-making, and fostering a systematic approach to sustainability.
Illustrative example of a DPP and the information that needs to be made available.
Why are DPPs important?
DPPs are not just another regulatory requirement to comply with; they present a strategic opportunity for businesses to unlock their sustainability performance, share data, ensure disclosure, and differentiate themselves. Here is why they are important:
DPPs will be key for regulatory compliance with the EU Ecodesign for Sustainable Products Regulation (ESPR), Batteries Regulation, and the upcoming revised Construction Products Regulation that mandate DPPs for various product categories, ensuring that all market products provide data on sustainability and circularity standards. This means that businesses need to adapt quickly or risk falling behind the curve and losing business to competitors who have their DPPs in place.
Access to detailed product information can unlock business value by driving innovation, optimising the supply chain, improving resource efficiency, and ultimately leading to cost savings and increased brand value. DPPs are also effective in mitigating supply chain risk. Enhanced data access and visibility across the supply chain can lead to better risk management and material optimisation.
DPPs will empower businesses to meet sustainability and disclosure requirements by providing transparency and access to product data on recycled content, repairability, and energy efficiency. They will also empower businesses to make their products more circular, enhancing longevity, reusability, and recyclability. As such, DPPs can also help track progress towards ambitious sustainability goals like achieving a fully circular product portfolio.
As customers will rely on data and DPPs from their suppliers, DPPs will be essential to meet customer expectations throughout the value chain. In particular, large companies that are ahead in meeting their disclosure requirements (e.g., set through CSRD and EU Taxonomy) will have procedures in place that prioritise working with those that have data on circularity metrics and DPPs readily available.
Illustrative example of a DPP and the information that needs to be made available.
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.