Digital Product Passports are just around the corner

Why it matters: challenges and opportunities.
 

The Digital Product Passport (DPP) is here. It arrives as a key facet of the wider green transition, and while some of the detail is yet to be decided, what is already clear is that the DPP promises to revolutionise the way companies operate across their value chain.

As ever, change brings with it both challenge and opportunity. Some businesses have proved alert to that opportunity; eventually, as DPPs become mandatory, all others must follow their lead. And if the compliance aspect of the DPP is self-evident, then it is also increasingly clear that its arrival is not without potential commercial benefits.

What is the ‘Digital Product Passport’?
 

The DPP is a key component of the EU’s Ecodesign for Sustainable Products Regulation (ESPR) (2024). As the name implies, a DPP is a digital passport that provides detailed, sustainability-related informationabout products or materials with the aim to improve their circularity.

The circular economy is about retaining the value of products and materials for as long as possible over the course of their lifecycle. Manufacturers of a product have information that could improve it’s circularity later in it’s lifecycle, such as information on repair or recycling instructions, but until now, they didn’t have an incentive to make this information easily available. The DPP aims to change this, by setting requirement to make this information available for actors across the value chain, such as resellers, users, or recyclers.

Increasing the availability of such data not only brings the opportunity for improved sustainability performance, but also grants companies the opportunity to demonstrate transparency to consumers and show themselves to be leaders in this space.

In the near future, businesses can expect to be subject to greater scrutiny from both regulators and the public alike. And though the transition is certain to pose challenges, the benefits of creating a robust foundation for sustainability data can reach far beyond the digital product passport.

Timelines and next steps
 

When is it going into effect?

• The Ecodesign Regulation entered into force in July 2024. However, as it is a framework regulation, there are not yet any immediate requirements for businesses to implement. The details of implementation are still under development and will be released in follow-up regulation called “delegated acts”.
• These delegated acts will include specific information requirements to be included in the DPPs for each product category that will be released alongside product ecodesign requirements, as well as provide the implementation framework for how the DPP systems will be set-up.
• The delegated act that will provide the details relating to DPP implementation is expected by late 2025. This will give us more information on the technical requirements of DPP.
• The delegated acts with product requirements for both DPP and ecodesign requirements will follow. The first delegated acts are expected to be adopted in 2026.
• Companies will be given a period to implement the requirements after the adoption of these delegated acts. Companies can expect to have up to 18 months, but it could be less or more, depending upon how difficult it will be for companies to adapt their manufacturing processes and operations.
• Therefore, companies can expect DPP requirements to apply as of 2027 or 2028.

Which industries and products are first?

• Initially, batteries will be leading the way. The requirements for the Battery Passport are defined under the new EU Regulation on Batteries and Battery Waste, and will already be a requirement as of 2027.
• Priority products and materials have already been identified that will likely be required to have DPPs: iron and steel; aluminium; textiles (including clothing and footwear); furniture (including mattresses); tyres; detergents; paints; lubricants; chemicals; energy related products (such as appliances) and technology products and electronics.
• The priority product and material categories will be defined in a DPP Working Plan, which is expected to be adopted by April 2025. The Working Plan will give greater clarity on which product cateogires will come first.
• The Working Plan will be developed by the Ecodesign Forum, which is a group of experts and stakeholders that will support the implementation of the Ecodesign Regulation.
• The Ecodesign Forum will also support the development of the specific DPP requirements and ecodesign requirements for the product categories in scope.
• Over time, almost all physical goods placed for sale on the EU-27 market will be covered by mandatory DPPs and the Ecodesign Regulation. Exemptions apply to medical products and pharmaceuticals, and products such as food, animal feed, or plants.

Get in touch:
 

Edward Sims

Director, Deloitte Global Ecodesign and Digital Product Passport Co-Lead (Denmark)