Policy Papers with recommendations for a DPP

The EU’s Proposal of the Eco-design for Sustainable Products Regulation (ESPR) defines product passports as “a set of data specific to a product that includes the information (specified in the correspondent delegated act of the product group) and that is accessible via electronic means through a data carrier.” 

There are still many questions to be answered by the EU on how exactly the DPP’s implementation will look. dss+ and ECOS worked alongside research and industrial partners to author 4 short policy papers that summarizes and makes policy recommendations for the DPP.  Each paper looks at the context of a DPP from four different perspectives: 

  1. Overview of a DPP 
  2. Recycling 
  3. Eco-design  
  4. Reuse & Repair 

Whilst the papers were submitted to the EU Commission for consideration of the policy recommendations made, they were purposely written for an audience who is not from a legislative background.  They can be read individually or as a series of 4.  The intention is for the papers to be shared beyond the CircThread consortium members to maximize impact by starting discussions and helping businesses consider how implementing a DPP will impact them. 

For example, companies placing products on the EU market will have to ensure there is a DPP available for their products. The DPP will apply to all products placed on the EU market, except for food, feed and medicinal products, and includes products manufactured in Europe and imported into the EU, therefore impacting global trade. The use of DPPs aims to gather data on a product and its supply chain and share it across entire value chains so all actors, including consumers, have a better understanding of the materials and products they use and their embodied environmental impact. 

When is DPP going to be implemented? 

The first delegated acts have already been adopted. This plan identifies a list of priority products for which delegated acts will be applied. Electronics, textiles, batteries and furniture are expected to be the most important categories to be addressed first by the Commission. Thirty new delegated acts are expected to be developed by 2030. 


How will DPPs impact your business? 

  1. Strategic Alignment with Regulatory Trends: 

The EU’s Eco-design for Sustainable Products Regulation underscores the mandatory inclusion of DPPs. Businesses aligning with this foresight gain a competitive edge in an evolving regulatory landscape. 

  1. Consumer Empowerment through Information: 

DPPs provide consumers with real-time, accessible information at the point of sale. This transparency cultivates a conscious consumer base, driving demand for durable and repairable products. 

  1. Elevating Sustainability Practices: 

Businesses leveraging DPPs gain insights into product quality, enabling more efficient repair and refurbishment processes. This not only reduces costs for consumers but also contributes to environmental sustainability. 

Challenges and Recommendations

The transformative journey of creating and using DPPs is not without challenges. The four policy briefs offer tailored recommendations to navigate these challenges effectively, ensuring a seamless transition towards a circular economy, including: 

  • Lack of “Use Phase” Information: Gathering data from consumers on how items are used and why they are discarded/recycled/repaired is so valuable in assessing a product’s environmental impact.   
  • Transparent Supply Chains: Achieving transparency across supply chains remains challenging. Businesses must prioritize efforts to develop comprehensive material composition information and trace materials, manufacturing processes, and waste management practices.  

  • Dynamic Regulatory Landscape: Adapting to evolving regulations requires business agility. Establishing cross-functional teams focused on sustainability and compliance is essential. The creation of feedback channels is critical to ensure knowledge gained from data sharing via a DPP allows future products to be better designed for circularity. 
  • Government-Industry Collaboration: Advocate for increased collaboration between governments and industries. This includes dialogue on challenges faced by businesses in implementing DPPs and working collectively towards viable solutions on topics such as verification of accurate input data, alignment with existing legal databases and reduction of administrative burden.  

  • Standardization Efforts: Engage with industry consortia and standard-setting organizations to contribute to the development of universally accepted practices, ensuring interoperability and reliability.   

For more insights, you can access the reports here:

Policy Brief #1

Policy Brief #2

Policy Brief #3

Policy Brief #4

Written by Radha Daniel, dss+