The Digital Product Passport, with Sophie Le Pallec

What is the Digital Product Passport and what are its objectives?

The Digital Product Passport (DPP) scheme stems from the European Union’s determination to make Europe the spearhead of eco-design and sustainable production. It is part of the general framework of the Green Deal, to be launched in December 2019. The Digital Passport is one of the provisions of the Ecodesign for Sustainable Products Regulation (ESPR), which was adopted by the European Parliament in April 2024 and came into force on July 18, 2024. First of all, it’s important to understand that the Digital Product Passport is part of a new, broader scheme, set up by the ESPR, which aims to eventually reserve access to the European market for eco-designed products, based on a whole range of criteria. In other words, the aim is nothing more and nothing less than to deny market access to products with inferior environmental credentials. Only products that meet the thresholds set by the European Commission will be able to enter the market, regardless of where they are produced.

The Digital Passport, which will then have to accompany certain items authorized to enter the market, will enable their environmental performance to be displayed and shared with all stakeholders, first and foremost the European consumer. The information will be accessible via the item’s unique identifier, encapsulated in a QR code, RFID chip (or any other appropriate means) and linked to the product, its packaging or leaflet. But by also setting information requirements, particularly those useful for the circularity of products between all players in the value chain, the Digital Passport should help to facilitate their second life, through repair, reuse and recycling, to limit waste and the destruction of unsold goods, and thus reduce our massive production of waste.

When and how will the digital product passport be implemented ?

The Digital Product Passport will only be compulsory for product categories that have been expressly covered by a delegated act. On the other hand, the regulation excludes from the outset food products, pet food, pharmaceutical and veterinary products, and vehicles powered by internal combustion engines.

In order to be applicable, the ESPR will therefore have to be supplemented by a whole series of delegated acts which will specify, in particular by product category, the information required and the deadlines for compliance. In parallel with the publication of these acts, technical standards will specify the technical and organizational architecture of the system: identifier, data carrier, data formats, data storage and access methods, etc. The European Committee for Standardization (CEN) and the European Committee for Electrotechnical Standardization (CENELEC) are responsible for publishing these standards by the end of 2025. However, given the progress of the work, the first standards will probably not see the light of day before spring 2026. 

Certain finished products (textiles, electronics, tires, detergents, etc.) and intermediate products (steel, iron, aluminum, plastics, chemicals, etc.) are considered priorities by the ESPR and should be included in the first delegated acts, publication of which should begin as early as 2026. In this way, we can expect the first compliance measures from 2027 onwards. For the time being, the European Commission is working on textiles and steel, and it is important that the companies concerned are aware of the challenges ahead. Alongside this “general regime”, certain sector-specific texts also provide for the implementation of a Digital Product Passport. This is the case for batteries, with Regulation 2023/1542 on batteries and battery waste, which will come into force in February 2027, but also for forthcoming texts in sectors such as construction or toys.

What’s GS1’s role in all this?

GS1 is a global, neutral and non-profit organization, created 50 years ago by companies in the world of commerce to provide a neutral forum for joint development of a common computer language. This was the beginning of the automation of commerce, which began with the widespread use of barcodes on products to automate checkout. 

The barcode encodes an internationally unique item identifier, the GTIN (Global Trade Item Number), which is used on millions of products, enabling information on a given item to be called up from all existing product databases. Today, with the advent of the Internet, the uses of the GTIN have far exceeded this initial function: consumer applications (Yuka, Open Food Facts) as well as those of the “Direction Générale de la Concurrence, de la Consommation et de la Répression des Fraudes” in english the General Directorate for Competition, Consumer Affairs and Fraud Control (SignalConso, RappelConso, DérogUkraine) use the GTIN as an access key to product data or to find the brand owner (GS1 Registers). 

In the future, companies will continue to use the GTIN to link up with new consumer information, such as environmental labelling, Nutriscore or the Digital Product Passport.  To facilitate this evolution, GS1 has standardized the information that can be encapsulated in a classic QR code, so as to be able to display several types of information, contextualized according to needs: no need to multiply QR codes on product packaging, just one is enough. This is why we now speak of “augmented QR codes”. At a time when packaging is becoming less impactful, it meets a crucial need for brands.

In addition to information capture elements, GS1 has a whole set of standards (data formats, exchange protocols), which enable service providers to already offer solutions that meet known regulatory specifications. We are working with numerous partners, notably within the European CIRPASS consortium, financed by the European Commission, on sector-specific pilots. 

What concrete changes will the Digital Product Passport bring to consumers’ lives?

The Digital Product Passport has several objectives: to help consumers make informed choices, to make information available to players throughout the value chain, and to improve the traceability of products throughout their life cycle. The information made available by the Digital Passport will be defined by product category, but must systematically provide information on performance, circularity (durability, recyclability), conformity and product use (e.g. manuals)

How do you feel about the reception of the Digital Product Passport by non-European players, who might see it as an attempt at protectionism?

The text has been strongly supported at European level by all stakeholders. On the one hand, it is consistent with Europe’s ambition to make production more sustainable, and not just from a carbon perspective. Secondly, it puts all producers, European and non-European alike, on an equal footing with regard to this ambition. Many European producers are making considerable efforts on the environmental front, but are penalized in terms of competitiveness by low-cost imports of mediocre environmental quality. They need to be able to objectify production practices that have less impact on the planet, in a way that consumers can understand. However, there is no guarantee at this stage that consumers will be prepared to spend more to choose products of better environmental quality.

France is known for being ahead of the game when it comes to eco-design measures: how does this translate into practice? 

France’s ambition is to enable French companies to anticipate the implementation of the DDP and to take a lead on the European market in terms of ESPR compliance and consumer visibility. In terms of eco-design, France has already taken a step ahead with the AGEC law (“anti-gaspillage pour une économie circulaire”) and the so-called “Climat et Résilience” law. The sustainability index, the environmental display and QCE (qualities and environmental characteristics) data for products and packaging, and the ban on the destruction of certain unsold products are just some of the French initiatives whose implementation has already begun, and which are preparing French companies for the provisions of the digital passport.