Brought to you by Michelle Wagner, Lucía Herreras Martínez and Pascal Leroy from the WEEE Forum

The European Union (EU) has long been at the forefront of environmental policy, particularly in addressing the growing challenge of electronic waste (e-waste). The Waste Electrical and Electronic Equipment (WEEE) Directive, first introduced in 2002 and subsequently recast, is central to these efforts. It sets targets for the collection, recycling, and recovery of e-waste, mandating that producers take responsibility for the entire lifecycle of their products. As technology continues to advance rapidly, the need for effective e-waste management has become increasingly urgent and one of the pillars for improving circularity. The EU has been developing innovative policies combining digital technologies with regulatory frameworks to create a more sustainable and circular economy for electronic products. 

Digital Product Passports

One of the most promising initiatives in this realm: the concept of Digital Product Passports (DPPs). These digital identity cards for products, components, and materials are designed to provide comprehensive information about a product’s lifecycle. In the words of the European Commission ‘this information will be accessible electronically, making it easier for consumers, manufacturers, and authorities to make more informed decisions related to sustainability, circularity and regulatory compliance”. It will allow customs authorities to perform automatic checks on the existence and authenticity of the DPPs of imported products. By 2026, the EU aims to implement DPPs for a wide range of products, including electronic devices, as part of its Circular Economy Action Plan. 

Benefits

The intersection of DPPs with existing e-waste regulations presents both opportunities and challenges. On the one hand, DPPs have the potential to significantly enhance the enforcement of e-waste regulations, allowing traceability at the product level from collection to pre-treatment. The information contained in the DPP will increase the effectiveness of e-waste management by providing detailed information about a product’s components, repairability, and recyclability. The DPP can notably help waste operators (from collection to preparation for re-use and recycling) to more efficiently process e-waste by: 

• Identifying products that contain components and substances that must be removed in the depollution processes; 

• Identifying parts that may contain critical raw materials, supporting the implementation of the Critical Raw Materials Act; 

• Identifying products with high re-use and repair potential;  

• Identifying products containing lithium-ion batteries (reducing the risk of fires and improving battery return rates); 

thus, potentially increasing recycling rates and reducing the environmental impact of discarded electronics. 

Moreover, DPPs can empower consumers to make more informed decisions about their purchases and disposal practices. By having access to information about a product’s environmental impact and recyclability, sensitized consumers may be more inclined to choose products with longer lifespans or those that are easier to repair and recycle and to dispose of the waste through licit routes. 

Challenges

However, the implementation of DPPs also presents several challenges. One of the primary concerns is the potential for increased administrative burden on manufacturers and retailers. The need to create and maintain detailed digital records for each product could be resource-intensive, particularly for smaller companies. The validation of such information is a key point in granting credibility to DPPs.  

Another challenge lies in ensuring the interoperability and standardisation of DPPs across different EU member states and industries. Without a unified approach, the effectiveness of DPPs could be limited. Similarly, information should not only be harmonised and validated, but also presented adequately, so it is understandable by the audience to which it is directed.  

Policy framework

Cognisant of these challenges, the EU is moving forward with plans to integrate DPPs into its regulatory framework. On 18 July 2024, the Eco-design for Sustainable Products Regulation (ESPR) entered into force. ESPR will establish a framework for setting eco-design requirements, including the implementation of DPPs. This regulation would work in tandem with existing directives such as the WEEE Directive. 

The implementation of DPPs has the potential to create a more holistic approach to product lifecycle management but requires careful consideration and coordination at the policy level. By providing a digital trail of a product’s journey from creation to disposal (cradle to grave), DPPs can help close the loop in the circular economy, making it easier to track, reuse, and recycle electronic components.  

As the EU continues to refine its policies around DPPs and circularity, it will be crucial to strike a balance between ambitious environmental goals and practical implementation. This may involve phased implementation, starting with high-impact product categories and low-hanging fruit, and gradually expanding to cover a wider range of products. Additionally, a DPP technology that will remain operative and with up-to-date information at the end of a life cycle of long-lasting appliances (PV panels may last over 25 years) is still under discussion. Moreover, the recycling sector often mentions the lack of accurate technologies for reading DPPs in bulk and affordable technologies that will allow to use of the information contained in DPPs.  

The success of this integration will largely depend on collaboration between policymakers, upstream suppliers, manufacturers, retailers, consumers and the waste management industry. Education and awareness campaigns will be essential to ensure that all stakeholders understand the value and use of DPPs in the context of e-waste management. Additional policies for developing supporting technologies would be welcome.  

Looking ahead

While DPPs in the EU are positioned as a significant step towards a more sustainable and circular economy for electrical and electronic products, their true impact will depend heavily on how they are implemented. It’s crucial to recognise that DPPs are not a one-size-fits-all solution. For instance, if consumers are indifferent to the recyclability or repairability of a product, the information within the DPP becomes irrelevant. Furthermore, if the data in the DPP is inaccurate, unvalidated, ambiguous or unclear, it can lead to misinformation and even contribute to greenwashing and unfair competition.  

The effectiveness of DPPs also hinges on their use by inspection bodies; without their engagement, DPPs will not help identify and address non-compliant behaviours. Furthermore, if recyclers and refurbishers lack the necessary technology to access and act on DPP data, the potential benefits of DPPs will be severely limited.  

It’s also important to acknowledge that DPPs are not a short-term fix; realising their full potential will require significant time, effort, and resources. While DPPs offer a promising tool for improving e-waste management, their success is far from guaranteed and will depend on overcoming substantial challenges in their implementation and adoption.