The Role of Digital Product Passports
The apparel & footwear industries are on a mission to design products that can be reused and recycled and Digital Product Passports (DPPs) are the key enabler of this transformation.
Supply chain transparency and compliance are an important and challenging piece of the data that brands are required to manage for a products lifecycle. In our recent webinar, we explore the evolving role of Digital Product Passports (DPPs) in navigating new regulations. The discussion covered key legislative overlaps, including California's SB-707 and the EU’s Eco Design for Sustainable Products Regulation (ESPR), emphasizing the significance and potential benefits of utilizing DPPs in managing compliance across regions. This session provided insights on how companies can proactively meet regulatory requirements while also enhancing consumer engagement through the use of DPPs.
California’s SB-707 shifts the burden of product waste management from local governments to producers, especially in the textile, apparel, footwear, and travel goods industries. This legislation mandates that producers take responsibility for the collection, recycling, and disposal of their products at the end of their life cycle, encouraging more sustainable production practices.
The SB-707 regulation has not specified labeling requirements yet. As a proactive measure, companies can adopt the Digital Product Passport (DPP) framework from the Eco-design for Sustainable Products Regulation for product identification and recycling. Implementing this framework has the potential to help companies enhance product traceability and streamline their compliance management.
The EUs Eco-Design for Sustainable Products Regulation (ESPR) requires producers of various products, including electronics, textiles, and furniture, to adhere to strict eco-design requirements aimed at extending product lifespans, enhancing energy efficiency, and reducing waste. Producers are mandated to ensure their products are durable, repairable, and recyclable.
The EU’s ESPR outlines data requirements, including the obligation for producers to issue Digital Product Passports. These passports must document a product’s environmental impact, recyclability, and compliance with sustainability standards, providing transparency throughout the product’s lifecycle.
The Eco-design for Sustainable Products Regulation is set to be fully implemented by 2030, with intermediate milestones along the way. Already active in 2024, companies operating within the EU will need to comply with stricter eco-design requirements. By adopting DPPs early, companies can streamline compliance and adapt more easily to global regulation changes. To learn more about the specific requirements and timeline for Digital Product Passports, download the presentation slides here.
Digital Product Passports (DPPs) have the potential to help companies align with both U.S. and European regulations, documenting a product's lifecycle and providing critical data for compliance with disposal and sustainability regulations. Additionally, DPPs offer transparency, allowing consumers to make informed choices based on product origins and environmental impact.
DPPs play a key role in bridging the gap between regulations like California’s SB-707 and the EU’s ESPR. Both pieces of legislation will outline detailed requirements for managing product lifecycles and reducing environmental impact, with the added expectation that companies adopt a more sustainable approach to production. DPPs have the potential to streamline compliance management by offering a data management framework that supports the likelihood of overlap in requirements between these regulations, ensuring a proactive and globally compliant strategy.
For a more detailed overview of the pending legislation, watch the full presentation here.
The webinar emphasized the importance of adopting a proactive approach to data management. Tracking product data from the fiber level through to the finished product is essential for meeting both SB-707 and ESPR requirements. A structured data management system not only ensures compliance but also creates cost efficiencies by reducing the time and resources needed to adapt to regulatory changes.
Download the webinar slides and watch the full recording here.
DPPs offer a dual benefit: they help companies meet legislative demands while also enhancing customer engagement. By providing transparency about product origins, materials, and sustainability credentials, DPPs foster trust and accountability. This opens up new opportunities for pre-purchase interactions with consumers, influencing buying decisions and building long-term customer relationships. For a more detailed overview of the pending legislation, watch the full presentation here.
Thank you to everyone who joined the live webinar. Please see below for answers to some of the questions we received during the live session. Our aim is to guide you toward the appropriate resources so that you can find the answers you need.
* Please note, while we strive to provide accurate and useful information, please consult qualified legal experts to ensure that the actions you take are tailored to your specific legal and regulatory requirements.
Topic: Eco-design for Sustainable Products Regulation
Yes, there are changes in the EU's most recent update to the Eco-design for Sustainable Products Regulation (ESPR) related to Digital Product Passports (DPPs).
The updated regulation emphasizes the introduction of DPPs across a broad range of products, aiming to enhance transparency, facilitate recycling, and enforce sustainable practices throughout product lifecycles.
You can find the specific information on the latest requirements here:
https://eur-lex.europa.eu/eli/reg/2024/1781/oj
This section elaborates on the specific data elements that must be included in DPPs, the accessibility of this data to various stakeholders, and the security measures that must be implemented to protect this data.
Topic: Ecodesign for Sustainability Regulation
Importers must ensure that each product has an accompanying digital product passport as per regulations, including a backup stored by a service provider. You can find all the details about Obligations of Importers in Article 29 in the link below.
Topic: SB-707
As far as we can tell, there is nothing that specifically mentions retroactive credits for current eco-modulation activities. The current legislation outlines how fees will be structured to promote sustainability, but there is no clear provision for retroactive credits.
If you would like to read the details, the eco-modulated fees are mentioned as part of the program's funding structure, which is detailed under Section 42984.14.
Source: https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=202320240SB707
The apparel & footwear industries are on a mission to design products that can be reused and recycled and Digital Product Passports (DPPs) are the key enabler of this transformation.
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Webinar Recap | Learn the latest on PFAS regulations, Extended Producer Responsibility (EPR), Digital Product Passports (DPP), and eFiling.