BIH: Sustainability in Focus: Digital Product Passport

Have you already heard about the digital product passport?

The European Commission plans to introduce the digital product passport (DPP) to enhance information crucial for product sustainability and circularity. It is believed that the DPP will facilitate the transition to a circular economy, improve material and energy efficiency, extend product lifespan, and ensure optimal disposal.

The introduction of the digital passport is mandated by Regulation (EU) 2024/1781 establishing a framework for setting eco-design requirements for sustainable products.

The regulation establishes a framework for determining eco-design requirements for products, which must be met to place them on the market or in use. The goal is to improve the ecological sustainability of products and reduce their overall carbon and environmental footprint throughout their lifecycle.

The regulation applies to all physical goods placed on the market or in use, including components and intermediate products. Only some products are exempt: food and animal feed, medical products, human-origin products, etc.

Accordingly, it is clear that DPP requirements also apply to chemicals. This aligns with the Chemicals Strategy for Sustainability adopted by the European Commission in 2020.

Eco-design of products should enhance certain aspects of products:

• extend durability,
• enable reuse or repair,
• reduce the presence of concerning substances,
• improve energy efficiency,
• reduce the expected amount of waste, etc.

Information about product aspects should be available throughout the entire supply chain, from manufacturer to consumer. This would lead to better resource management and reduced environmental impact. Given the vast amount of data that cannot be listed on a product label, the solution is found in electronic information dissemination.

How is the digital passport envisioned?

The digital product passport is an electronic document, or a set of data specific to a particular product, available electronically via a data carrier. The data carrier can be a linear barcode, a two-dimensional symbol (QR code), or another medium for automatic recording of identification data readable by a device.

The DPP should include all information about product aspects relevant to its sustainability, increasing transparency and better informing users. However, it is essential to find a balance between transparency and protecting confidential business information.

Many questions about the DPP remain open. For instance, it is still undefined whether the DPP will apply to a product model or a series. However, some basic requirements are known:

• The DPP should be linked to a unique product identifier,
• the data carrier must be physically present on the product,
• personal data of product users must not be stored in the DPP without their explicit consent,
• access to data must be free, and the level of available data may depend on the type of user (buyer, manufacturer, customs authority, etc.).

The regulation foresees the establishment of a DPP registry and a publicly accessible internet portal where product data can be searched and compared.

Given the vast number of different product groups, defining eco-design requirements and introducing the DPP will be done gradually. It is anticipated that the first group of regulated products will include detergents, paints, lubricants, and other chemicals.

All products will need to prove compliance with eco-design requirements, for which a declaration of conformity will be issued. Additionally, products will need to be marked with the CE conformity mark.

It is worth mentioning that a revision of the European Union's CLP regulation is underway, which anticipates the introduction of digital labels for chemicals. Bojan Buinac has provided an overview of the basic requirements for digital labels, which you can view here.

This is certainly a topic we will discuss much more. But for now, this is enough.

What are your thoughts on the changes aimed at better product sustainability? Let me know at nina.pajovic@bens-consulting.eu.