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DPP Implementation: Expectations and Challenges of the Electrical and Electronics Value Chain

Brought to you by Elise Vermeersch and Elena Fernandez from UNITAR

The rising demand and limited supply of critical raw materials (CRMs) hampers the ability of European Union (EU) industries to rapidly adopt technological change towards green and sustainable technologies, and to achieve Green Deal objectives for an equitable, zero-emission, and digitalized Europe.  

One of the key measures to minimize the loss of secondary raw materials (SRM) and optimize their reuse across value chains is to bridge the information gap that exist among actors of the same value chain. To address this challenge, the European Commission (EC) is preparing general requirements for the establishment of digital product passports (DPP) within the scope of the Circular Economy Action Plan (CEAP)

In a nutshell DPP is a tool that gathers data on a product and its value chain, with the objectives to support sustainable production, enable the transition to the circular economy, provide new business opportunities to economic actors, support consumers in making sustainable choices and allow authorities to verify compliance with legal obligations. DPP is being introduced in a number of EU laws, including in the proposal for the Ecodesign for Sustainable Products Regulation (ESPR) and in the Battery Regulation proposal for the Ecodesign for Sustainable Products Regulation (ESPR). 

With the aim to understand value chain actors’ expectations, anticipated challenges and requirements for the implementation of DPP, the CE-RISE project has carried out a stakeholder consultation targeting both industry representatives and consumers. This consultation was mainly based on online questionnaires and collected 43 stakeholder responses from the industry sector and 75 responses from consumers. 

Value chain actors have rather high expectations of DPP but are concerned of the numerous challenges that may hamper its implementation. 

According to the industry respondents, DPP could increase transparency between producers and highlight environmental compliance costs. Recording socio-environmental information in DPP could facilitate open market conditions, healthy competition, and social awareness. DPP could also provide the information necessary to identify hazardous, problematic, and valuable materials, maintain product useful life and ensure optimal disposal or reuse, contributing to the circular economy. However, industry actors expect difficulties obtaining the data to include in the DPP due to resistances from stakeholders, concerns over data confidentiality and the risk of sharing such data with competitors.

Thus, data sharing is at the heart of the DPP concept but remains one of the main challenges to overcome. The lack of resources for implementing DPP (including money, time, and personnel), and the lack of technical expertise and infrastructure are also major concerns. 

Among consumers, DPP is seen as a tool to provide information and promote virtuous behaviours, both from the consumers’ and companies’ sides. DPP could help overcome the current challenges faced by consumers when looking for product-related information, especially the difficulty in finding neutral, reliable, and comparable information (especially environmental-related information), the lack of transparency and clarity about the product evaluation criteria, and the complexity of the information.

At a higher level, DPP could help reducing the environmental footprint of a product, encourage more responsible consumption patterns and raise awareness about environmental and socioeconomic issues. However, so far, not every consumer is informed about the concept of DPP, which means that some awareness raising should accompany the development of DPP to make sure a majority of consumer is informed about this new tool at their disposal. 

The successful implementation of DPPs will depend on the trust and usefulness that stakeholders will place in them, it is thus of paramount importance to know precisely what data they want to have access to via the DPP. 

In terms of data requirements, it is not surprising that each industry stakeholder is primarily interested in data points that would facilitate and improve their daily work.

Producers, manufacturers, and component suppliers would like to see information related to the products footprint (environmental impact and material footprint), and information about standards and regulations.

Reuse and repair organisations would like to see information regarding the recycling and disposal instructions, the carbon footprint and energy efficiency metrics, the products repairability and ease of disassembly, and the product lifespan and expected durability.

Refurbishers and remanufacturers would like to see information regarding the product history, the availability, price, and where to find spare parts, the products age, and the upgradeability of a product.

Recyclers would like to access information related to product composition, specifically, the type, quantity, and location of CRMs, hazardous substances, and batteries.

Retailers stated it is important for them to share information about the products they sell with their customers, and they would like to see information related to environmental impact, product lifecycle information, and material composition and toxicity information. 

From the consumer’s perspective, the main type of information to be included in a DPP relate to the products’ repairability (i.e., whether a product can be repaired, refurbished, remanufactured), age and repair history, the environmental impact information, the potential recyclability of the product, the socioeconomic impact information, and the products’ and materials’ origin. 

Data requirements will thus be a key aspect to address in future legislation and DPP development to ensure the commitment and contribution of the various actors of the value chain. 

Building from the stakeholder consultation, the CE-RISE project will further investigate legal requirements and current experiences to address the main challenges identified and implement the conclusions and recommendations driven from this process.