The use of digital product passports

Considering the recently-introduced European sustainability legislation and how it affects producers of goods which are directly placed onto the European market.

by Nicola Pichel-Juan

The European Union’s Ecodesign for Sustainable Products Regulation (ESPR) entered into force on 18th July 2024 as a key element of the EU’s drive for more sustainable and circular products. It replaces the Ecodesign Directive 2009/125/EC and provides a framework for Ecodesign requirements for certain product groups, including those within the fashion and textile sectors.

At a high level, the aims of the ESPR are to i) improve product durability, reusability, upgradeability and repairability, ii) make products more energy and resource efficient, iii) reduce the presence of harmful substances – as well as substances that inhibit recycling, iv) make products easier to recycle, v) set rules on carbon and environmental footprints, and finally vi) improve the availability of information on product sustainability. One of the requirements resulting from ESPR is that of ‘digital product passports’ (DPPs).

What is a digital product passport?

A digital product passport is a collection of hundreds of relevant data points about a product which are then made available to other relevant parties. This could include other businesses within the product’s supply chain, enforcement agencies (such as customs authorities and trading standards), and the final consumer of the product.

The DPP would typically be accessed by scanning a ‘Quick Response’ (QR) code or a ‘Radio Frequency Identification’ (RFID) chip that is either printed onto or incorporated into the product itself or would form part of its packaging or labelling. The information provided would be related to the product’s performance, sustainability and circularity credentials. Different levels of data access would be granted to different user types. For example, some data would be available to the public, and some would only be made available to enforcement agencies.

The requirement for DPPs will be gradually phased in over the coming years. The first product group to require mandatory DPPs is certain types of batteries from 2027. Further sectors – such as fashion and textiles (including footwear) and furniture – will be required to have DPPs from 2030.

The requirements of a footwear DPP

The exact data requirements for footwear DPPs are yet to be confirmed by the EU. However, based on the requirements for other product categories and information required by other pieces of EU legislation, it is likely to include information such as the following.

Unique product identifiers such as product names and product codes.

Information about the materials used in the product – what the material is, its composition, where it was sourced from, any associated material certifications, and details on compliance with restricted substances legislation such as REACH.

Product information – where the finished item was produced, potentially including evidence of compliance with local labour regulations and information about the expected durability of the product being manufactured.

Sustainability credentials – for example, if the product has certifications for any sustainability claims being made, such as having recycled content, the origin of the materials, or the product’s carbon footprint.

User instructions – information provided to end consumers to advise them on how to care for and maintain the item to keep it in use for as long as possible. Information on how to repair the product and where it can be repaired may also be required.

End-of-life – information for consumers on how to dispose of an item responsibly at the end of its life, which may include information about any authorised take-back schemes or where an item can be disposed. The information contained in the DPP would also be accessible to companies such as recycling facilities to help them to understand what the product is made from to determine the best way to process it.

Challenges

The amount of data that is likely to be required for a DPP may seem onerous. However, many companies within the footwear sector will already have access to, or be gathering, some of this information for their own purposes or to comply with other legislative requirements for supply chain traceability and reporting.

Footwear supply chains can be long and complex, sometimes crossing multiple countries or even continents. For instance, larger companies may be sourcing the same product from several production sites spread across different origin countries. In some cases, the materials and components used to manufacture the same finished product may also be sourced from different ‘second-tier’ suppliers.

It is therefore likely that the DPP data will not only need to be managed at a unique product level, but also at a production batch or purchase order level. This is likely to be a significant IT undertaking, as the information required may be held across multiple systems (such as Product Lifecycle Management (PLM) and Enterprise Resource Planning (ERP) systems). The data will in turn need to be made available to integrate with a DPP platform or solution. There are many companies already offering DPP solutions, and it is expected that the EU will also put in a place a central registry where all DPPs created can thereafter be stored and accessed.

There are also benefits for organisations implementing DPPs, including increased customer engagement and protection against counterfeiting. Having the necessary DPP data available will also facilitate various other reporting requirements as well as supporting ongoing efforts to transition to a circular economy.

How to prepare?

SATRA recommends that any companies which sell footwear and other products into the EU that will be affected by DPPs start work now to gather as much information as possible about their products and product supply chains. It is important to begin to build business processes and IT systems to facilitate the collection and management of the data that is likely to be required. Although the data requirements for footwear DPPs have not been finalised, any companies which do the work now to put the necessary framework in place will be in a much better position to adapt and include any additional data once the requirements have been finalised.

The rest of the world

DPPs are an initiative of the European Union and only affect goods directly placed onto the European market. Nevertheless, there is already existing and planned legislation in many other countries calling for the disclosure of similar information to that required in the DPPs. It is therefore highly likely that it will be normal going forward for organisations to need to provide much more detailed information about their products.

Publishing Data

This article was originally published on page 14 of the November 2024 issue of SATRA Bulletin.

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