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We always look to further enrich this section by progressively including new questions and answers that might arise. By sending us your questions, you will be helping the entire DPP community! Thank you!

 

** Fresh FAQ items **

General

  • We sincerely hope that our deliverables will be useful to support the ongoing European standardisation effort by CEN & CENELEC. We regularly present our work in standardisation committees and some CIRPASS partners are participants of national mirror groups. Seeing the huge work that this standardisation effort will represent over 2024 and 2025, we hope our analyses will be judged useful and constructive.
  • The latest ESPR (Ecodesign for Sustainable Products Regulation) draft following the December 2023 agreement between European Parliament and Council can be found here > https://www.consilium.europa.eu/media/69109/st16723-en23.pdf (Note that minor changes may be made before official adoption and publication in the Official Journal, which will likely occur in the summer of 2024.) Article 16 2b) on the Prioritisation working plan states (Note that this Article refers to the ESPR as a whole and not necessarily for the DPP.)
  • “In the first working plan, [to be adopted no later than 9 months after the entry into force of this Regulation], the Commission shall prioritise the following product groups: – iron, steel – aluminium – textiles, notably garments and footwear – furniture, including mattresses – tyres – detergents – paints – lubricants – chemicals – energy related products, the implementing measures for which need to be revised or newly defined – ICT products and other electronics. If any of those product groups is not included in the working plan or if any other product group is included, the Commission shall provide a justification for its decision in the working plan.”
  • Looking briefly at the MOBI website, we see that they are proposing digital identities for vehicles in order to offer vehicle-based services. In Europe, to the best of our knowledge, vehicles have been explicitly excluded from the ESPR and the DPP, because vehicles are already subjected to many other ecodesign regulations. Some of the technology used by MOBI, e.g. distributed identifiers and verified credentials may also play an important role for the DPP in the future. While not mandatory, the DPP may also operate over a blockchain. However, these technologies are not part of what CIRPASS refers to as the “core DPP system”.

On Technology

  • The DPP does not “pull” information from multiple dataspaces. The economic operator placing the product on the market will have the obligation to collect (through any means they wish, including automatic mechanisms) the mandatory DPP information and expose this DPP data in the proper format.
  • The mandatory DPP information (both public and restricted access) requirements will be defined in the upcoming ESPR delegated acts for each individual product group. It is not known today if “Traceability certification” will be part of this mandatory data set. For information, CIRPASS is also in favor of non-compulsory information content in the DPP.
  • Many companies are already selling “DPP-like” solutions today. There are several hundreds, but more likely thousands of such companies, most of which are sector specific. CIRPASS actively promotes a DPP system architecture flexible enough to facilitate the interoperability of these existing solutions.

About relevance of EU law

  • The ESPR states that access to mandatory DPP data should be free of charge. The fees for DPP data hosting services (referred to as ‘certified independent third-party product passport service providers and backup storage providers’ in the ESPR) will be left to the market. CIRPASS hopes that there will be thousands of these, if economic operators e.g., manufacturers, do not want to host their own DPP data. Hopefully, these service providers will propose additional data services to their customers, ideally alleviating the burden of DPP-issuing fees.

  • The latest ESPR draft available here https://www.consilium.europa.eu/media/69109/st16723-en23.pdf states (Article 9) “personal data related to the customer of the product shall not be stored in the product passport without the explicit consent of the end-user in compliance with article 6 of Regulation (EU) 2016/679”.
  • The responsibility for DPP data remains with the economic operator placing the product on the market.

** Older FAQ items **

General

  • Guidance on the DPP will depend on the outcome of the discussions on ESPR.
  • The DPP will be open source. The DPP should be able to work with the already existing databases in the EU, so companies will not need to put data in multiple databases.
  • Assuming that there is a need to trace this repair in a DPP, i.e., the delegated act requires item-level granularity for this product, the ownership of the DPP and responsibility for hosting the DPP data always remains with the operator responsible with putting the product on the market. The authorization to amend the DPP data will be conveyed through national authorized practitioner registries.

  • If you already included the details of your initiative in the CIRPASS registry of DPP initiatives, we thank you for that.
    If not, we invite you to fill in the details of your initiative here. Note that information provided will be considered to be in the public domain.

  • A Digital Product Passport (DPP) is a structured collection of product related data with pre-defined scope and agreed data ownership and access rights conveyed through a unique identifier and that is accessible via electronic means through a data carrier. The intended scope of the DPP is information related to sustainability, circularity, value retention for re-use, remanufacturing, and recycling.
  • CIRPASS is the Consortium which won the European Commission’s call for proposal: DIGITAL-2021-TRUST-01-DIGIPASS-Digital Product Passport: sustainable and circular systems 
  • The CIRPASS Consortium is made up of 31 partners and is led by CEA of France
  • CRIPASS stands for ‘’Collaborative Initiative for a Standards-based Digital Product Passport for Stakeholder-Specific Sharing of Product Data for a Circular Economy’’
  • To create an inclusive forum to build a common understanding of a cross-sectoral DPP 
  • Build stakeholder consensus on DPP prototypes in three sectors: Batteries, Textiles and Electronics 
  • Focus on building a cross-sectoral DPP system  
  • Build/align terminology surrounding the DPP
  • A DPP prototype is a simple description of a DPP including agreements and suggestions on all aspects including: data, technical, semantic, organisational and legal.
  • The CIRPASS Project has an 18-month timeline, it started in October 2022 and runs until March 2024. 
  • There are three departments in the European Commission that are steering the project: DG Connect, DG Grow and DG ENV
  • The DPP will be mandatory for all product groups regulated through delegated acts of the ESPR.

(Recently added question/answer)

  • A huge number of companies are developing DPP “pilots” and solutions. We list a large number of DPP-related initiatives in the public report we have published on our website, and we hope to increase this list in the coming months.  All initiatives are warmly invited to add their contribution to this report.

    CIRPASS is not a standardization body. We are working to help the Commission understand the missing standardization activities that will be necessary to enable the DPP system. In parallel, as our understanding about the future DPP and DPP system improves and evolves, we try to communicate this to the wider community so that we all globally share the same level of understanding of what the DPP is, and what it is not. Our aim is that the companies that are within the CIRPASS consortium have the same level of understanding and preparation for the upcoming DPP as all other companies outside.  We study currently ongoing pilots to learn from them and help the Commission understand if it is going in the right direction.

(Recently added question/answer)

  • No. The choice of the three focus sectors was defined in our original work plan. However, CIRPASS is regularly in touch with and exchanging with initiatives in many other sectors.
  • See the consultation here
  • The DPP will impact every actor along the full supply chain.
  • The European Commission expects DPPs on the market in 2026/2027.
  • In the long term, the DPP will push for the provision of information on carbon footprint. However, currently the focus is on product circularity.  
  • The Consortium is working to include as many initiatives as possible.
  • The job of recording and analysing existing DPP initiatives is an ongoing part of the CIRPASS project.
  • CIRPASS is a Coordination and Support Action for the European Commission. This involves gathering all available information in relation to DPPs, including information on more than 100 existing prototypes. system.
  • DPP, like any new policies and innovation, is likely to face resistance from certain stakeholders. That is why one of the mandates of CIRPASS is to build stakeholder consensus and support, as well as educate stakeholders. In addition, EU policy makers have acknowledged that certain stakeholders such as SMEs may face more challenges in implementing DPP policies, and need support.
  • There are no manufacturers within the consortium in order to avoid giving the impression that the project’s recommendations might favour one company over another. However, open consultations and targeted workshops will include manufacturers and other stakeholders during the entire project duration.
  • At the moment, an important first step is “speaking the same” language through the use of a common terminology. A major difficulty at the moment is that all DPP stakeholders are coming to the DPP with different perspectives, objectives and understandings.
  • CEA is the coordinating organization of CIRPASS. CEA is not involved in Catena-X. To the best of my knowledge, CEA is not involved in Gaia-X (but CEA is very big, so I may be mistaken). CEA is a research institute with a mission of innovation for industry. The fact that CIRPASS is coordinated by a research institute is a guarantee of technological neutrality.

SME Related Questions

  • Guidance on the DPP will depend on the outcome of the discussions on ESPR.
  • The DPP will be open source. The DPP should be able to work with the already existing databases in the EU, so companies will not need to put data in multiple databases.
  • Assuming that there is a need to trace this repair in a DPP, i.e., the delegated act requires item-level granularity for this product, the ownership of the DPP and responsibility for hosting the DPP data always remains with the operator responsible with putting the product on the market. The authorization to amend the DPP data will be conveyed through national authorized practitioner registries.

DPP System & DPP Data

  • The ESOs will work on developing standards for the DPP, and it is expected to become international in the coming years. 
  • While the details of the DPP for specific product groups will be defined in specific delegated acts (See ESPR summarization for more detailed information), it is advisable that DPP policy makers and developers should take into consideration major related standards in developing and implementing DPP policies and guidelines.
  • The DPP-system is the set of IT standards and protocols that will be needed to make the DPPs work (with full interoperability in mind). The DPP-data is the set of information that will be included in each DPP, and that will be product-group dependent.
  • The current scope includes information on sustainability, circularity, and value retention for reuse/remanufacturing/recycling.  
  • The issue of granularity will be defined in the delegated acts and will be specific to individual product groups.
  • The DPP is not a QR code. A QR code is one of the possible types of data carriers which might be used to carry the product’s unique identifier.
  • Blockchain-based services that might be of value to the DPP will be evaluated in the context of the project. 
  • This is one of the challenges being examined in designing DPP. In other words, the topic of DPP granularity is a consideration in order to balance DPP cost, usefulness, and data availability. 
  • Authorisation to update and access data, as well as the timing and frequency of information updates are among the DPP design issues that this project is taking into consideration.
  • Blockchain technologies might be an enabler for certain applications, but it should remain possible to build DPPs without these solutions. Distributed here means that the data will remain where it is created, allowing DPP providers to keep control of their data. Access right permissions to the data will be role-based.
  • Connectors will indeed be necessary.
  • Semantic web technologies will also play an important role in the DPP.

DPP Governance

  • The goal is to have a non-proprietary solution
  • The European Commission is planning to set up Circular Economy Hubs across the EU to help businesses adjust to the new regulation around circularity.
  • The ESPR regulation is expected to be finalised in 2023. The delegated acts are revised every 3-5 years.
  • The DPP will be designed as a decentralised system, therefore, no large EU database is foreseen.  A thin registry is expected, but its access may be limited to surveillance authorities and governments
  • Specific sectoral legislation is expected to follow the roll out of DPPs which will address these issues. For example, in the Battery Regulation, it is stated that the operator responsible for issuing the DPP will have to file a declaration of conformity. Certain data points, such as CO2 footprint and recycled content will have be audited by conformity assessment bodies.
  • By ensuring full interoperability and open standards.
  • ESPR will introduce requirements that affects products from both inside and outside the EU.
  • The actor that puts the product on the market will be responsible. 
  • Access to data will be on a need-to-know basis. It is expected that certain actors will have access to specific subsets of data.
  • Product passports shall be designed and operated so that a high level of security and privacy is ensured and fraud is avoided.
  • The passport registry is centralized and managed, but not the passports themselves. It is expected that the passports are created and maintained by economic actors.
  • Having DPP as a vehicle to fulfil the compliance to multiple EU regulations for all product categories is unlikely in the near future as DPP policies and implementation are still at an early stage. However, DPP is likely to help facilitate and streamline the monitoring and enforcement of the regulations carried out by the EU and member state authorities.
  • DPP policies, as part of ESPR, are a European Union initiative, and the grant is designated toward member state organizations. However, it is acknowledged that supply chains are globally intertwined, thus European Union DPP policies are very likely to have an impact beyond the EU borders.
  • The regulations and related delegated acts will define the actor groups that should have access to sensitive information, e.g. repair shops who will be identified using official professional registries. Other business B2B agreements for access to specific data should additionally be possible.