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High hopes, harsh realities: Towards an EU digital product passport

Panel: 9. Products, appliances, ICT

Authors:
Thomas Adisorn, Wuppertal Institute, Germany
Lena Tholen, Wuppertal Institut für Klima, Umwelt, Energie gGmbH, Germany
Thomas Goetz, Wuppertal Institut für Klima, Umwelt, Energie gGmbH, Germany

Abstract

While discussions on a Digital Product Passport (DPP) are not new, both the EU’s Green Deal and Circular Economy Action Plan have given new impetus to the DPP as a potential policy instrument for a sustainable product policy in the EU. Amongst others, the DPP is supposed to provide information on a product’s origin, its composition as well as repair and disassembly possibilities and on handling at the end of its service life. In the end, a DPP may draw a comprehensive picture of product-related information valuable to many stakeholders such as suppliers, manufacturers, retailers, customers, professional repairers, waste treatment facilities as well as market surveillance authorities.

However, depending on the passport’s exact design and granularity of information, it may require rethinking of current product policies, including those on energy efficiency (also to reduce red tape). For instance, in the field of energy-related products, the Ecodesign Directive, the Energy Labelling Regulation or the Waste from Electrical and Electronic Equipment Directive (WEEE) define product information and specify information flows between stakeholders, determining the roles of information providers and information takers.

We start with highlighting the role of a circular economy for the EU’s ambitions to achieve climate neutrality. In particular, the European Commission seeks to strengthen the role of circularity in National Energy and Climate Plans.

Then, we will sketch preliminary design characteristics of the DPP based on information published so far. In doing so, we’ll have a close look at policy documents and other literature published since 2019 on the EU level and in Germany, including the EU’s Green Deal, the Circular Economy Action Plan, the Sustainable Products Initiative and Germany’s Digital Agenda for the Environment. We seek to draw a schematic picture on possible information flows envisioned in the DPP involving all relevant stakeholders in a product’s value chain.

Given that electronics are seen as a priority group to investigate upon the implementation of a DPP in the EU and Germany, we focus on energy-related products and illustrate how flows of certain types of information are regulated through selected EU regulation such as Ecodesign , Energy Labelling and WEEE. In this respect, information on energy consumption is a distinct feature of energy-related products in comparison to other products such as textiles. Still, especially Ecodesign increasingly focuses on circularity aspects. For instance, a vacuum cleaner’s hose and motor have to survive 40.000 oscillations and 500 operating hours, respectively (Annex I of Commission Regulation No 666/2013). For electronic displays, manufacturers, importers or authorised representatives shall provide access to the appliance repair and maintenance information to professional repairers (Annex II of Commission Regulation 2019/2021).

After a brief comparison of information flows envisaged by the DPP and implemented through Ecodesign, Energy Labelling and WEEE, we discuss the potential role of the European Product Database for Energy Labelling (EPREL) in a future DPP regulation. Recently, EPREL was implemented providing a central system for manufacturers to submit important (and regulated) product information. For some, the idea behind EPREL serves as an interesting example for future DPP activities as some information is intended to remain confidential with access rights only to authorized stakeholders (e.g. market surveillance authorities), while other information is publicly available. Furthermore, much could be learned from success and failure experiences gained during the implementation of EPREL.

In the end, we derive questions, which need to be answered in the coming years as precondition for the DPP as part of the EU’s overall product policy.

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