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ANSI Roundtable Explores the European Commission’s Digital Product Passports

2/29/2024

The American National Standards Institute (ANSI) convened a roundtable of public- and private-sector stakeholders this week to gather input and share information surrounding the European Commission’s (EC) proposed Digital Product Passport (DPP), a component of a much broader effort by the European Commission to move companies and manufacturers toward developing products that are more sustainable.

DPPs, which share product information across the entire product lifecycle, are being introduced by the EC as a means to increase transparency and unlock circularity. Currently, the EC is finalizing a comprehensive regulation—the Ecodesign for Sustainable Products Regulation (ESPR)—that includes a DPP requirement, with final approval expected this year. The DPP is a so-called “data carrier” that must be affixed to all products that fall under ESPR. It may take the form of a QR code, RFID tag, or other form of scannable technology. As required by the ESPR, the DPP will contain a host of information about a specific product and its sustainability.

According to the EC, the information compiled for DPPs “will be easily accessible by scanning a data carrier and it will include attributes such as the durability and reparability, the recycled content, or the availability of spare parts of a product. It should help consumers and businesses make informed choices when purchasing products, facilitate repairs and recycling, and improve transparency about products’ life cycle impacts on the environment.”

Batteries will be the first product category to be legally required to comply with DPP, sometime in 2026, with apparel and consumer electronics following shortly thereafter. The Digital Product Passport will eventually be required for roughly 30 categories, with the implementation timeline spanning from 2026 to 2030.  

Many elements of the DPP—such as scope (application level), technology (storage, carrier, and access), and data (data requirements and governance)—remain open, with different levels of maturity in the EU’s DPP proposal. The EC has proposed that the DPP be discussed within the U.S.-E.U. Trade and Technology Council (TTC) framework, both with respect to standards and conformity assessment aspects, as well as market access aspects.

In response, ANSI convened a member roundtable to solicit input on possible areas of cooperation between the U.S. and EU on DPPs that would help shape this EU initiative in a way that is aligned with the U.S. private sector priorities.

Led by ANSI senior vice president of government relations and public policy Mary Saunders, the roundtable discussion raised areas of opportunity and potential concerns regarding DPPs. Several attendees questioned the EU’s definition of “international standards”; too narrow of a definition could exclude standards developed by non-EU-based standards developing organizations. In order to expedite the process and achieve the highest degree of ecodesign quality, a broader and more flexible view of international standards should be considered when setting technical regulations.

Another topic of discussion was the proprietary information disclosure that may be necessary under the DPP. In addition to concerns about the proliferation of sensitive data, attendees discussed potential requirements for third-party holders of data: who holds this data, and how will it be compartmentalized? Will the accuracy of the data be verified, and if so, who will verify it?

Roundtable participants pointed out the notable differences in how digital information can be tied to products in different categories. How can end users be assured that they are in possession of the actual product associated with that data?

ANSI will continue to share relevant information on the DPP with its members and constituency as the EC regulation progresses. The Institute thanks all roundtable participants for sharing their thoughts and expertise on this emerging area of standardization.

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