The EU Commission is planning to introduce a digital product passport. This simplifies the exchange of product-related information between companies, actors in the supply chain, authorities and consumers. The information is to be made available online in a compressed form. The plan is to make all relevant information available about a product, including, for example, the materials from which the product is made, information about spare parts and repairability, energy consumption, and disposal of the product. The information can be accessed, for example, by scanning a QR code on the product via an app that retrieves the information from a database (product passport register). The digital product passport is intended to ensure longer shelf lives and duration of use for products. This will promote recycling management and contribute to achieving the EU’s 2050 climate targets. At present, there is no concrete timetable for implementation; previously, a rollout was planned for 2022.
The digital product passport solves many problems with regard to operating instructions and user information that were previously required as hard copies due to differing legal framework conditions. In order to implement the digital product passport, however, the more than 70 directives and regulations that currently stipulate corresponding requirements for product labeling and instructions must be adapted at the European level.
In the draft for the new Ecodesign Regulation published on 30 March 2022 there are framework conditions for the digital product passport. Article 8 sets out requirements for the provision of information and Articles 9–11 set out rules for implementing the product passport. The Ecodesign Directive already gives preference to repairing energy consuming products rather than disposing of them. With the adoption of the Ecodesign Regulation, regulations could be extended to other sectors and product groups.
To better enforce ecodesign requirements, national authorities and the Commission are to have direct access to data carriers. Standardisation bodies, industry associations, consumer organizations, experts and international partners are also to be involved in the concrete design.
We will start by establishing the digital product passport for resource and energy intensive goods such as batteries. In this regard, the Battery Regulation is to replace the Battery Directive in the future. The Battery Regulation is slated to contain requirements for the entire product life cycle of a battery. According to the current status, the Regulation will come into force at the beginning of next year. Numerous amendments are currently being discussed. It can be assumed that demand for batteries will rise sharply in the coming years, particularly due to the increasing integration of electric vehicles in road traffic.
Summary
To date, there have only been product specific regulations on certain phases of the product cycle, for example for domestic appliances. Now, product specific information must be provided digitally and meet increased transparency requirements. Companies can get involved in the design of digital product passports and already develop an internal implementation concept for them. The technical implementation of a product passport is also a challenge that has not yet been solved and will only be meaningfully resolved with the participation of industry.
However, companies can expect a uniform solution to product information requirements in the medium term that will be resource efficient and practical.
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