Guest post written by Melanie King
As the EU continues to advance its sustainability agenda through the Circular Economy Action Plan, recent legislation has placed a significant focus on promoting sustainable products and increasing transparency through enhanced data requirements. Two key components of this legislative framework are the Ecodesign for Sustainable Products Regulation (ESPR), which entered into force on 18th July 2024 and the new Battery Regulations, where enforcement commenced on 18th February 2024. The ESPR includes a number of new measures, including Digital Product Passports (DPP), rules to address the destruction of unsold consumer products and green public procurement. as well as specific regulations like the EU’s new Battery Regulation (Regulation 2023/1542). These initiatives are critical for manufacturers in the EU market, particularly those producing products that contain batteries, to understand and comply with.
The intersection of these regulations creates additional complexity, especially for electronic and electrical products and organisations introducing batteries and battery-powered products to the market. This applies to any economic operator involved in making batteries available in the EU, whether as separate components like cells, modules, and packs, or as part of larger products. It also includes those who change a battery’s intended use or are involved in refurbishing or remanufacturing. A key feature of the regulation is the mandatory inclusion of a QR Code on all batteries, facilitating the use of ‘smart label’ and ‘battery passport’ functionalities, varying by battery type. While specific operators are obligated to provide this information, in practice, a broader network of stakeholders will likely contribute, creating an integrated, multi-stakeholder ‘product and battery information ecosystem’. This ecosystem will span the entire value chain and lifecycle of battery products, supporting both passport and smart label functions with information from a diverse array of operators.
In theory, the DPP will facilitate easier access to detailed information about a product’s materials, components, and compliance with environmental standards, as well as each supplier’s sustainability credentials. This transparency is expected to aid in recycling processes, product repairs, and even in resale markets, thereby supporting circular economy objectives. The system will use unique identifiers and data carriers to link physical products with their digital counterparts, ensuring secure and efficient data access. However, one of the primary challenges is the absence of standardised data formats for the information required in the DPP and data exchange protocols. This lack of standardisation can lead to inconsistencies and difficulties in data integration across different products and industries.
For instance, the data required to track the lifecycle of batteries, including materials used, performance metrics, and recycling information, can vary significantly between manufacturers. Without standardised formats, the information provided by different companies may not be directly comparable, complicating efforts to ensure compliance and transparency. Another significant issue is ensuring the integrity and verification of data included in the DPP and Battery Passport and smart labelling. The DPP system is expected to include robust mechanisms for data authentication and reliability. However, developing a uniform standard for data verification poses challenges, particularly in industries where supply chains are complex and involve multiple stakeholders. For example, ensuring the accuracy of data related to the carbon footprint of products requires consistent methodologies across different sectors. Currently, there is no single framework that all industries can adhere to, leading to potential discrepancies in reported data.
Interoperability is another critical challenge. The DPP aims to make product data accessible and usable across various systems and platforms. However, differences in data systems and software used by companies can hinder this goal. There is a need for interoperable systems that can seamlessly integrate and exchange data across different stakeholders, including manufacturers, regulators, and consumers.
The lack of common data standards can also affect the traceability of products, especially in complex supply chains. For the Battery Passport, which includes detailed information on battery components and materials, interoperability issues can impede the flow of information necessary for recycling and compliance verification. The regulatory landscape for product data transparency and sustainability reporting is still evolving. As such, there are differences in how regulations are interpreted and implemented across the EU member states. This variability can lead to challenges for companies operating in multiple jurisdictions, as they must navigate different sets of requirements and standards, particularly with regard to what icons and information should appear on labels in different countries.
These challenges highlight the need for a coordinated effort to develop and implement standardised data formats and protocols. At the Open Product Initiative, we are actively engaged in developing standards and tools that will assist manufacturers in meeting these new EU requirements. Our focus is on creating comprehensive and standardised data templates (initially for electronic and electrical equipment and batteries) that can be used across organisations and supply chains, simplifying the process of data collection and reporting for the DPP, Battery Passport and smart labelling.
These legislative changes represent a significant shift towards sustainable product design and transparency in the EU market. For manufacturers and producers, especially small and medium-sized enterprises (SMEs), understanding and adapting to these requirements poses a substantial challenge due to limited resources and expertise. The Open Product Initiative remains committed to supporting this transition, advocating for the adoption of open data standards. Such standards are essential in reducing the compliance burden on SMEs, ensuring that they, alongside larger industry players, are well-equipped to meet these new regulatory challenges.
If you’re interested to get involved sign up to one of our upcoming events or find out more by getting in touch.
For a write up of our research findings so far check out our other blog – What we’ve learned about the (waste) electronic and electrical equipment ecosystem so far and what’s next
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“European Union Flags 2” by DesignRecipe is licensed under CC BY 2.0.