How to Prepare for DPPs (Digital Product Passport)

Written by Protokol

For any business, major operational changes can be challenging – especially when these changes are specifically mandated for compliance with new regulations. This is exactly the case for organisations that intend to manufacture or sell physical products within the EU over the next decade as they grapple with how to prepare for DPPs.

In December 2023, the EU Commission reached a provisional agreement on a new Ecodesign for Sustainable Products Regulation (ESPR), which will set design and performance standards for specific product groups, intended to improve their sustainability, energy performance, and overall circularity.

Recognising the need for up-to-date and accessible product information to enforce the legislation, the ESPR will require affected product groups to contain Digital Product Passports. For some industries such as Textiles, DPPs must be in place by 2030, with many other industries like Consumer Electronics and ICT to follow suit.

While penalties for non-compliance haven’t yet been specified, they may include fines, confiscation of assets, and business sanctions, leaving organisations to ponder over how to prepare for DPPs and implement them effectively before their respective industry deadlines.

1. RESEARCH THE RELEVANT REGULATIONS

Firstly, organisations need to understand which of the new regulations (if any) apply to them. If you manufacture or sell physical products within the EU, there’s a high chance that at least one of them will affect your organisation.

For example, the Battery Passport Regulation mandates that DPPs in the form of battery passports must be integrated and accessible via QR code for some battery products as early as 2027, such as:

  • Batteries in light means of transport (LMT)
  • Industrial batteries with a capacity greater than 2 kWh
  • Electric vehicle (EV) batteries

For Construction, the Construction Product Regulation seeks to improve the data flow for construction products, adopting a wide scope of information that is to be contained in those specific DPPs.

The main piece of legislation to understand, however, is the ESPR, which will mandate DPPs for as many as 30 product groups. Some product groups such as Textiles/Apparel have an implementation deadline of 2030 for DPPs, with other industries set to follow suit in the years after.

These include (but are not limited to):

  • Consumer Electronics
  • ICT
  • Furniture
  • Chemicals
  • Plastics

The ESPR applies not only to products manufactured in Europe but also to those being sold within the EU, meaning global manufacturers and retailers are not exempt. The industries exempt from the ESPR are food, feed, and medicinal products. Even if it’s still unclear which of the legislation above applies to your organisation after doing some research, it’s still beneficial to invest in a DPP solution.

Not only do DPPs help with the stringent compliance requirements of the updated CSRD and CSDDD laws by providing quality sustainability information, but they also deliver very real operational value in enhancing product authenticity and traceability, improving supply chain visibility, and enabling more thorough product lifecycle analysis.

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