The first step toward compliance with the ESPR’s digital product passport mandate

This regulation will affect the industries and products considered to have the worst impact on the environment, such as electronics, and will apply to businesses that place products in the EU market.

While the legislation’s role in promoting circularity and sustainability is becoming clearer to companies, the practical steps required to comply with the ESPR – and particularly its Digital Product Passport (DPP) mandate – are still somewhat of a mystery to many. One of the first crucial steps for those who need to comply will be identifying and validating the relevant data for DPPs, something that will require a considerable effort for many businesses. 

Lars Rensing, CEO of Protokol, DPP Solution Provider, further discusses.

An overview of the ESPR

As part of the EU’s Circular Economy Action Plan (CEAP), the ESPR aims to enhance circularity and sustainability by establishing a framework that makes "sustainable products the new norm in the EU." This regulation aims to improve product longevity, increase energy and resource efficiency, facilitate repairs and recycling, reduce harmful substances, and support the incorporation of more recycled content within the supply chain.

The implementation of DPPs, which securely host event, transactional, and sustainability-related information throughout a product’s lifecycle, will be an essential step in supporting this effort, and as such, they have been mandated for compliance.

Although the guidelines outlining the specific information required in DPPs for various industries and product groups – via the delegated acts – have yet to be announced, data collection and validation will be an obvious first step.

It is also going to be one of the biggest challenges due to data often being spread out across the value chain, in complex internal and external systems. As a result, many businesses are keen to begin preparation by identifying and mapping their data ahead of the mandate to ensure they’re in the best shape for compliance.

Below I outline six key steps businesses can take now to begin their DPP preparation journey:

1. Collaborate with your stakeholders to establish your current position

To begin with, communicate with stakeholders across the supply chain, such as suppliers, manufacturers, and logistics partners, to build an understanding of the product sustainability data currently available. This will help create a comprehensive overview of available product data. Additionally, engaging in these discussions can uncover previously unknown information and spark conversations about how to enhance data transparency and accessibility throughout the supply chain.

2. Perform a data gap analysis to identify missing information 

Once the data has been collected and identified, it’s advised to conduct a data gap analysis considering the elements that are highly likely to be required in a DPP. In the electronics industry, this may be information on the carbon footprint of the manufacturing process of the product, or information for end-users on safe end-of-life disposal to reduce the number of devices being sent to landfill. This will help to identify any existing data gaps within the business, allowing you to explore solutions such as integrating measurement tools or partnering with new collaborators.

3. Conduct a Life Cycle Assessment (LCA) audit to start addressing data gaps

Once data gaps are identified, prioritising a Life Cycle Assessment (LCA) is essential. This process assesses the environmental impact of a product's lifecycle and can start from raw material extraction to offer a comprehensive perspective.

4. Verify data sources for accuracy and peace of mind

Throughout these steps, it's crucial to validate data sources to create an accurate, verifiable picture of each product. This involves evaluating the credibility of third-party data providers and ensures that processes are aligned with relevant standards.

5. Assess DPP solutions to ensure seamless integration

As DPP solutions are so complex, creating a solution in-house won’t be a viable option for most businesses. In this case, they’ll need to seek out suitable partners who are experts in the creation and implementation of DPPs with specific electronic industry challenges in mind.

The implementation of DPPs is key to compliance, as such, understanding how data needs to be inputted, and the resources required to ingest data into the DPP system is crucial to capturing and storing data in the correct formats. It’s also important to consider whether the DPP solution can integrate with existing systems and how it provides an ongoing, real-time view of a product’s lifecycle.

6. Begin a pilot to trial and evaluate

Once all the above steps have been completed, it’s important to launch a pilot to test implementation and create together a more accurate picture of the scale and timeline for the full task. At this point, electronics businesses will be in a much better place to kickstart efforts once the delegated acts are announced. This pilot step will enable businesses to assess the interoperability of their DPP solution, allowing them to evaluate whether the new system integrates seamlessly with existing IT systems and supply chain management platforms.

A pilot will also mean businesses can evaluate the ‘user experience’ of their processes and the accessibility of key information. Achieving compliance with the ESPR’s DPP mandate depends on a strategic, systematic approach that includes efficiently collecting, validating, and integrating environmental data throughout the supply chain to meet regulatory requirements.

Taking the first step to business compliance with the ESPR

While there are still ongoing uncertainties around the release of the delegated acts, businesses can still take a proactive approach to DPP compliance to ensure they aren’t on the backfoot once they are announced. As one of the key industries earmarked as a priority, this is especially important for electronics businesses at the start of 2025.