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EU Digital Product Passport: A Complete Guide

What is a Digital Product Passport?

A Digital Product Passport (DPP) is a digital record containing all the information relating to a product’s lifecycle. Any and all information such as the product’s origin, the materials used for making it, the impact it has on the environment, disposal, and recycling viability at the end-of-life are included in the digital product passport. The aim of DPP as proposed by the EU is to make products more sustainable and thereby promote a circular economy model.

The Purpose of Digital Product Passport

The driving factor behind the digital product passport initiative from the EU is to promote a sustainable and circular economy by reducing wastage and conserving resources by reusing them along with making product lifecycle more transparent.

There are two main goals here:

  1. Take the next step in sustainability
  2. Make product information as transparent as possible

The goal of digital product passports is to make product-related data accessible to everyone so that we know how a product is made, what it is made of, where it was made, and how to recycle the product.

DPP proposes to include the entire lifecycle information of a product, from source materials to end of life management. The information proposed to be included in DPP is unavailable in the current system, making DPP a significant improvement over the current system.

By providing detailed information about products such as its origin, materials, environmental impact, etc., DPP helps both businesses and consumers alike. Consumers can make informed decisions during purchase and businesses like supply chain partners can stay compliant and support the circular economy initiative.

Since DPP is not applicable for just companies in the EU, companies across the world should start planning for DPP if they plan to sell products within the EU, even if the product does not originate from the EU.

DPP is important for companies that plan to enter the EU market in the future as well since DPP will become mandatory by 2026 for some industries of importance.

In addition, staying compliant, especially for non-EU companies, gives them a competitive advantage over companies that are not yet compliant.

The Role of Circular Economy Action Plan (CEAP) in DPP

CEAP aka Circular Economy Action Plan was the triggering regulation for digital product passports. The goal of CEAP is to enable sustainable product design and manufacturing, reduce waste, and recycle as much as possible.

The European Green Deal

The European Green Deal is the broader picture and CEAP is only a part of it. The Green Deal aims to make the EU climate-neutral by 2050.

Circular Economy Action Plan

Instead of the current model of manufacture, consumption, and disposal, the EU is pushing for the process to be circular. In the circular model, instead of fully disposing of a product, it should be recycled and reused as much as possible. Even if the entire product cannot be recycled, some of its components must be recycled.

To know what’s reusable and what’s not, we need to know what a product is made up of and that’s where DPP comes into play.

There are some other EU regulations that are connected to CEAP.

Circular Textiles Strategy

 This is another part of the CEAP that is specifically aimed at the textile industry. Since textiles are one of the industries that produce a lot of waste, it is crucial to implement CEAP in textiles.

The Battery Directive

The battery directive is a regulatory framework created just for batteries since they are one of the large sources of waste and are hard to dispose of and recycle. Since there is a rise in electric vehicles (EV) and the EU wants to make EVs sustainable, there is a special focus on batteries in CEAP. The goal just like other products mandated in CEAP is to enable circularity and enhance the reusability of batteries.

What Does the DPP Look Like?

We understand that DPP contains all the information relating to a product. But what does a digital product passport look like?

DPP is a digital record. Meaning, it is to be accessed electronically. What that can look like for consumers is a mechanism for scanning, like a QR code, NFC, RFID,  barcode, etc., and a platform that will display the information.

In layman’s terms, if you scan the QR code on a product you purchased, your phone will just open a browser window or a pre-installed application that contains the information about the product you scanned.

Such a system is nothing new. Most companies out there already have a website.

What makes DPP different is the type of information that’s displayed. The EU regulation makes it clear that the entire lifecycle of the product must be included in the DPP.

If we take a step further, a separate QR code can be provided for consumers and partners. Consumers might not need to see very detailed and technical data whereas vendors, distributors, and partners can benefit from all the details of a product.

Proprietary information can be hidden or given access to specific users, which can be protected via login credentials.

What Needs to be Included: Data Requirements & Components for Digital Product Passport

EU has specified the type of data that’s required for products. The type of data can change for each industry and type of product. The important core data are:

Product Identification

Products need a unique identifier for them to be recognizable and to be able to connect to the data stored in DPP.

Materials and Origins

The materials used in the production of each product along with the origin information are required along with sourcing data. This includes the recyclability of each raw material as well since the objective is to identify how much of a product’s components can be reused.

Environmental Impact

This is related to how environmental damage an item can create, and the carbon footprint of the product throughout its production lifecycle. The energy and resource consumption information also need to be included.

Safety and Compliance

Products have to stay compliant with certain regulations depending on their type. Safety and compliance data refers to information on regulatory standards the product has to meet, health and safety information, warnings, and other risk mitigation information for the safe handling of the product.

Repair and Maintenance

Repairing products is important for CEAP as it reduces wastage. How repairable a product is, past repair data, and the availability of spare parts and other components needed for repair and maintenance are to be included in DPP.

Ownership, and history

The ownership history, along with the supply chain history of the product and its components.

Disposal Information

What to do with the product at the end of life and how to dispose or reuse the product or its components.

Digital Product Passport Implementation Timeline

Even though the European Green Deal has set a deadline of 2050, the implementation deadline for DPP is much sooner. The pilot program for certain industries has already started. Currently, the objective is to gather information on how the standard needs to be.

As per the timeline provided currently, 2026 will be the transition year to move from planning to the implementation phase for industries with significant environmental impact. 

This means textiles, electronics and batteries are the first to begin implementation.

Mandatory requirements for certain product categories, such as batteries, will follow in 2027.

The new EU Battery Regulation mandates that starting in February 2027, all traction batteries, two-wheeled vehicle batteries, and industrial batteries with a capacity of over 2 kWh must have a digital EU battery passport. This also applies to LMT (light means of transport) batteries used in e-bikes and e-scooters. 

Industries and Products that need to Implement DPP

DPP will need to be implemented in all industries that produce products. There are some important sectors that will need this done earlier than others due to the amount of wastage such products create.

Batteries

Batteries are one of the most important products expected to be managed under CEAP as battery usage has skyrocketed after the growth of the electric vehicles industry. It is also hazardous and difficult to dispose of and recycle.

Textiles and Fashion

Textiles and fashion industry produce waste in large quantities. Information on the materials of origin, dyeing process, and recyclability of clothes are expected to make this industry more sustainable.

Electronics

Electronics such as smartphones and laptops are being purchased at least every two years by most consumers, which creates large amounts of waste. Just like batteries, electronic components are harder to recycle and dispose of, making the electronics industry one of the primary targets of the CEAP.

Implementing DPP: Challenges

The major challenge in implementing DPP is the data itself.

DPP mandates all product information to be made available in a uniform digital format.

Collecting, maintaining, and standardizing the data is more challenging than implementing the technical infrastructure needed to store the data.

Scattered and Fragmented Data

To begin with, there is no standardized format that companies follow at the moment to maintain all the information needed for DPP.

Although the information is available, it is often dispersed across multiple sources.

All this data needs to be brought together and stored in a centralized system for it to be accessible from a single interface.

Data Quality Issues

Since there was no need to maintain the type of data (origin, materials, etc.) required for DPP, compiling them for the first time would result in serious data quality issues.

Companies would have to invent processes and workflows for collecting and validating the data.

Automation and Process Challenges

Since most companies do not have the digital infrastructure to create information for DPP, it would be a challenge to consolidate everything into one place.

Manual data migration could take a long time, so automation is more effective. Also, a process needs to be developed for consolidating, verifying, and then centralizing the data.

The Role of Product Information Management (PIM) Solutions in DPP

Product Information Management, aka PIM, is a solution that has existed for a long time. The purpose of a PIM system is to store and manage product information.

Until now, PIM systems have been used as a single source of truth for product data. This data would then be displayed across various channels, such as websites, mobile apps, portals, etc.

There are two of the major pillars of technology required for DPP:

  1. A mechanism to store product data
  2. A delivery and distribution system for customers and vendors to access the product data

A PIM system can be part of the solution for this requirement.

PIM systems can be customized to store additional information needed for DPP.

This does not mean that a PIM system can act as a DPP. Instead, the PIM system can potentially become one of the pillar components of DPP and can work together with other systems to realize DPP.

A headless PIM system is an asset for implementing DPP because:

  • Data management can be centralized
  • Making changes to product data is easier using the visual editors available in most PIM systems
  • PIM systems are usually compliant with regulations
  • Integration with existing systems is possible

The Digital Product Passport requires comprehensive documentation and proof across the entire supply chain, including certificates, to ensure full transparency throughout the entire product lifecycle. All the relevant technical data can be centrally managed within the PIM system. Certificates and other documentation can be stored, managed, and directly assigned to the respective products or components, enabling efficient and compliant data management.

Implementation Strategy for DPP

More planning is needed in identifying the data and deciding on a structure for the data rather than the implementation of a software solution for storing the data.

The data requirements for DPP are  complex. We not only have to include the product information, but the entire lifecycle and raw material information also have to be included to be compliant.

Decide Data Standards and Requirements

The first step is identifying the data to be stored and creating a hierarchy and model for the data. A standardized data structure makes it easy to maintain .

Collaborate with Partners

Close collaboration with the individuals that consume the information stored in DPP is required to ensure that the solution is effective. Understand their data requirements and incorporate them into the plan.

Building the Digital Infrastructure

Choose the best solution for storing the data. PIM systems make an ideal candidate for DPP. Keep in mind that the DPP and CEAP are in the early stages and can evolve and change in the upcoming year. So, it is critical to choose a PIM system that can adapt quickly to changes and at the same time stay compliant with all the data protection requirements in the EU.

Do Companies Outside the EU Require DPP?

Regardless of a company’s location, if they intend to sell products within the EU, they should have DPP. Remember the goal is to create a circular economy within the EU, which is only possible if all the companies that operate and sell within the EU stay compliant.

Final Words

DPP is new to the business world and is still in the planning and evolving phase. But the tight deadline makes it important to act on it as quickly as possible. The industries that could be affected should start planning for DPP as soon as possible to stay compliant.