Julie Brown
Head of Sustainability, EON
June 1, 2022

All you need to know about the EU's Digital Product Passport legislation

Upcoming global legislation will soon require a new, deeper level of product data transparency across the retail industry. One such mandate -The EU’s Digital Product Passport (DPP) legislation - will change the way the industry collects and shares product data along the value chain, and is set to have a wide-sweeping impact on commerce as a whole. Learn more about the policy from our FAQ below:

1. What are Digital Product Passports?

Digital Product Passports (DPPs), used here interchangeably with Digital IDs, digitally record, process, and share product information among supply chain partners, authorities and consumers. Their intention is to improve traceability and transparency, and to support after-sale services such as repair, resale, and recycling. In order to be effective, the information must be standardized so it can be shared and exchanged across the retail value chain – from manufacturers to retailers, resellers, recyclers and more. Consumers also benefit: digital product passports are linked to a scannable label on the physical product such as a QR code or NFC tag that enables customers to access product information to inform their purchase decisions and help prolong the lifespan of their products.

2. Will  Digital Product Passports become mandatory?

DPPs are a key component of the Ecodesign for Sustainable Products Regulation (ESPR), and this strategy calls for the regulation to define details regarding how the DPPs will operate.

The adoption of this policy is expected in 2024, when requirements for DPPs across various sections are created. Sectors such as Batteries and Textiles are prioritizing DPP implementation alongside finalizing requirements. The EU Strategy for Sustainable and Circular Textiles, released in March 2022, calls for DPPs to be mandatory on textiles sold in Europe by 2030. Find more information on our blog.

3. Who is affected and when will Digital Product Passports be mandated?

All companies putting products on the EU market fall under the scope of the ESPR. The strategy was presented to the European Parliament in Spring 2022. It is expected to be approved by 2024, when details such as data requirements and scannable on-product labels such as QR codes and NRF tags will be written.

4. What will be the requirements of a Digital Product Passport?

The proposed general ESPR requirements for digital product passports include the following:

  • It shall be connected through a data carrier to a unique product identifier.
  • The data carrier shall be physically present on the product, its packaging or on documentation accompanying the product.
  • The data carrier and the unique product identifier shall comply with standard (‘ISO/IEC’) 15459:2015.
  • All information included in the DPP shall be based on open standards, developed with an interoperable format and shall be machine-readable, structured and searchable.
  • The information included in the DPP shall refer to the product model, batch or item.
  • The access to information included in the product passport shall be regulated in accordance with the essential requirements set out in Article 10 and the specific access rights at the product group level shall be identified in the applicable delegated act adopted pursuant to Article 4.

While the exact data fields have not been defined and will require additional studies and impact assessments, here are some of the potential information requirements that have been prioritized for ESPR:

  • Water consumption during production per kg or unit of product
  • Possible release of non-biodegradable microplastics
  • How to manage the textile or footwear at the end of its lifetime
  • Possible lifetime of the textile or footwear
  • GHG emissions associated to the production of a clothing item
  • Percentage of recycled content in product packaging
  • GHG emissions associated with the washing and drying operations of a clothing item
  • Energy consumption associated to the production of a clothing item
  • Energy consumption associated with the washing and drying operations of a clothing item
  • Expected lifetime of the product
  • How to use the product to avoid its premature substitution/replacement (or of its components)

Examples of proposed data requirements for DPPs

5. How will this affect EON or the Circular Product Data Protocol (CPDP)?

A number of specific requirements have recently been defined for DPPs, and EON is working to ensure all requirements will be met through our technology and data protocol. Until then, EON offers a network of partners and features that will likely be aligned with future requirements of the DPP. Also, EON is and will continue to take all opportunities to share the value of the CPDP and best practices for implementation to assist with policy development as much as possible.

The CPDP is governed by an Advisory Council who is responsible for ensuring that the protocol remains up to date and in line with policy. This council will continue to review legislative progress to understand what data requirements are expected and ensure that they are captured in the protocol.

6. What is EON doing to prepare?

CIRPASS is a consortium of 30 industry partners laying the groundwork for DPPs. Funded by the European Commission under the DIGITALEUROPE program, CIRPASS aims to prepare brands for piloting and deployment of DPPs from 2023 onward, with an initial focus on the electronics, batteries, and textile sectors. EON is a member of CIRPASS’s Expert and Stakeholder Group. As part of this Group, EON is informing the DPP legislation and continuously optimizing the tools and technology to keep clients ahead.

7. What do I need to do to prepare?

Digital IDs are already available for brands to adopt today and there’s no better way to prepare than to get started. EON is digitizing billions of products for global brands, ensuring they meet the objectives already described in the EU policy proposals. Product demos are available upon request to explain how our solution works. Another good place to start is by collecting prioritized product data to meet the traceability and transparency objectives of the ESPR. The CPDP can act as a free resource to learn more about the type of data policies could include.

For brands that have already adopted Digital IDs, extending digitization to your entire portfolio can save you time in the long-run and offer valuable insights and commercial benefit.  EON clients are leading the industry and proving the value of Digital IDs for those that will need to eventually comply with the legislation.

Lastly, we are committed to keeping our clients and community informed on this topic. Subscribe to our newsletter for key information and learnings regarding Digital Product Passport policy.

8. Why should we invest in Digital ID now?

Eventually, all brands selling in Europe will need to have Digital IDs implemented and there will be a deadline to do so. If brands are not prepared, they could run into any challenges and miss out on sales. Those that get ahead of this policy will be industry leaders.

Regardless of policy, there are many impactful commercial reasons to invest today in Digital IDs. Products with Digital IDs can be shared instantly with value chain stakeholders throughout their life cycles, engage customers and deliver insights, unlock new after-sale services and business models such as resale, rental and recycling, and increase operational efficiency.




The road to Digital Product Passport


March 2022: EU Strategy and ESPR draft released


End 2023: Draft data requirements expected


Early 2025: Delegated Act expected for Textiles and Footwear


Late 2026/Early 2027: DPP implementation requirements expected for Textiles and Footwear

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