Article

The “Digital Product Passport” Under Scrutiny

It sounds almost ideal: With just a few clicks, we can find out everything about a product—where it comes from, under what (social and environmental) conditions it was produced, and what materials and components it contains. But also how we can repair or dispose of it. According to plans by the European Commission, this is set to become possible through a Digital Product Passport—or DPP for short.

Transparency across the entire value chain is becoming increasingly important—and not just for end consumers. We also need it to transition from a waste-based policy to a product-based policy, in line with the “New Circular Economy Action Plan.” The DPP can be a crucial lever, particularly for circular economy tools such as repairing, refurbishing, repurposing, and recycling.

A Closer Look at the European Commission’s Plans

The Digital Product Passport is intended to filter the minimum necessary data sets from the widest possible range of stakeholders—across the business-to-business, business-to-consumer, and business-to-government levels. The real challenge lies in implementing complex data processing, identifying the “right data,” and designing an appropriate legal framework. The latter is particularly necessary to ensure that important information is made available even when stakeholders have differing interests.

Stages of the value chain extend beyond national borders and involve a wide range of stakeholders. The key now is getting the design right. The Commission is currently examining various implementation options and has already initiated a dialogue with various stakeholder groups. According to the Commission, the “Sustainable Product Initiative”—which includes the Digital Product Passport—is scheduled to be published in March 2022.

What members of our initiative think

BASF is a member of the BDI Circular Economy Initiative and offers insights into how the Digital Product Passport is also a key concern for companies in the chemical industry. Christine Bunte is Head of Corporate Advocacy at the chemical company’s Ludwigshafen site. She emphasizes that what constitutes “accurate information” depends primarily on the recipient:

“BASF supports the approach of making relevant information transparently available to ensure the safe and sustainable use of chemicals throughout the value chain. In doing so, we are engaged in practical projects aimed at developing sector-specific solutions. For example, CatenaX and the Global Battery Alliance are working to develop a Battery Passport to provide transparency regarding the origin of raw materials in production and to enable recycling after the batteries have been used. Crucial to successful implementation is, first and foremost, coordination and dialogue with stakeholders in the value chains to ensure that the right information is made available. Here, it may be advisable to provide different types of information depending on the needs of the parties—our industrial customers have different requirements than end consumers. To learn as much as possible from existing initiatives, experience with previous regulatory initiatives, such as the SCIP database, should also be taken into account. Protecting confidential business information is essential to maintaining competitiveness in Europe.”

BSH Home Appliances is also a member of the BDI Circular Economy Initiative. For the company, proximity to end consumers—and thus the trust they place in the company—plays a major role. Christian Dworak, Corporate Operations Steering Advisor, on the European Commission’s plans:

“A Digital Product Passport must be based on harmonized regulations within the EU and should not duplicate other, already existing specifications (in particular international standards for material declaration, such as IEC 62474). Consistency and alignment with existing requirements of other EU legislation, such as the REACH Regulation or the ECHA SCIP database, are necessary to avoid duplication of effort in providing information. To this end, the concept should be structured as a decentralized system rather than a central database. The DPP must be linked to existing databases—and ideally extract or replace data from them—while avoiding duplication and overlap.

Suppliers of end products in the EU cannot be held responsible for all content in the DPP that accumulates throughout global supply chains. For example, the manufacturer of components and materials is also responsible for the information regarding them. Responsibility for information concerning the entire life cycle of devices (repairs, remanufacturing, recycling, etc.) must therefore be borne by those who actually upload the information.”

Following an initial workshop on the Digital Product Passport with experts from industry, academia, and the Commission, the BDI’s Circular Economy initiative will continue the dialogue on this topic in the coming months.

Contact

Jury Flickenschild

Project Manager Energy, Transport and Environment
Industrie-Förderung Gesellschaft mbH