KANBrief 3/25
Digital product passports will provide helpful information for numerous product groups in the future. The affected parties have been working on the passports’ introduction and the opportunities they offer for the circular economy and occupational safety and health since the Ecodesign Regulation was published in the summer of 2024.
The EU Ecodesign Regulation for sustainable products, which came into force in the summer of 2024, introduces the concept of digital product passports. Many updated legal texts in product law now also include the requirement for such a product passport. Examples are the Batteries Regulation, the Construction Products Regulation and the future Toy Safety Regulation.
A digital product passport is a product-specific data record that can be accessed electronically, for example through a QR code. It contains a wealth of information on performance characteristics, and mandatory information such as the unique product identifier, conformity documentation, user manuals, instructions for use, warnings or safety instructions, manufacturer’s information and the CO2 footprint. The data varies according to the product group, and is specified in product-specific regulations or associated delegated acts.
Product passports enable product information relevant to safe use, repair and recycling, including information concerning the safety of human beings and the environment, to be made available to all parties across the value chain and throughout the product’s life cycle. Product passports are intended to promote the circular economy and make sustainable products the norm.
Rights to access the data differ for each economic operator, according to the operator’s function. The product passport can be used by companies to combine the information with that of other products. This makes digital product passports useful for creating digital twins of complex products. It also enables the entire life history of a product to be tracked. This in turn may facilitate a wide range of services relating to reprocessing, repairability, reuse, second life, recyclability and new business models. A further aspect is the possibility of tracking raw material extraction/production. Consumers can use the data to make informed purchasing decisions.
Product passports also support market surveillance and customs authorities in the performance of their duties. In particular, the provision of reliable information to authorities and policymakers supports them in assessing risk assumptions and developing appropriate options for action.
The primary purpose of the digital product passport is the sustainability of products. However, it also offers opportunities for improving occupational safety and health. Workers in a wide variety of jobs are involved in the individual stages of product manufacture, use, repair, reprocessing and recycling. For employers, the product passport could become an important source of information for risk assessment. If an employer is aware of what hazards a particular product poses, or of where substances giving grounds for concern are to be found in the product, it is easier for them to take appropriate protective measures for different activities. The information contained in the product passport is particularly important during the planning phase, for example for the construction of new installations, as retrofitting or subsequent modifications are usually very costly, and often not even possible, for technical or structural reasons.
Not all information in the digital product passport is relevant in all phases and for all parties involved over a product’s life cycle. It is therefore all the more important that information on risks, known for example from the manufacturing process, is available to repair and recycling processes, and vice-versa. For example, the fibres of carbon fibre materials become thinner and shorter only after repeated shredding processes. This increases the risk of the fibres entering the lungs and the body being unable to degrade them. In this scenario, a risk suddenly arises at a point in a product’s life cycle that was not relevant during the use phase of the original product. If such knowledge of risks is retained down the value chain, workers can be better protected.
Digital product passports will become mandatory by law successively for all product groups. The battery passport is planned for 2027. It will be followed by other product groups, beginning with textiles, construction products, toys, mattresses, furniture, and detergents and cleaning agents. The technical requirements for this process are still in preparation. The standards sector has already begun intensive work on establishing harmonized structures, thereby making a major contribution to implementation of the digital product passports in the field. The form to be taken by the content will follow, and is already dictated in part by the statutory requirements. Whether it will be advantageous to launch standardization work on content relevant to occupational safety and health has yet to be seen and discussed.
Implementing the digital product passport system in industry and making the data accessible in a standardized form will entail considerable effort for all parties involved. One advantage is that a large amount of information is already available at the various points along the value chains. Once digital product passports have been implemented, they can also support compliance with the requirements for documentation, verification and due diligence. It is to be hoped that the potential of this communication tool will be exploited to the full across sectors and regulations, as the European Commission intends with its Single Market Strategy.
Nicoletta Godas
Federal Institute for Occupational Safety and Health (BAuA)
godas.nicoletta@baua.bund.de