DPP - The Background
Governments and regulating authorities became concerned about the' global impact of industries' in the 2000s. The European Commission proposed the IPP (Integrated Product Policy) to monitor and reduce the environmental impact of goods and products sold in the European market. The WEEE (Waste Electrical and Electronic Equipment) Directive and REACH Regulations focus on the electronics and chemical industry.
From 2009 to 2012, with the expansion of the Ecodesign Directive, things started to move towards Circular Economy and Digitalisation. Initially focused only on Electronics, but eventually covering the whole market. 2015 marked the first viable action plan for the EU's Circular Economy.
The European Green Deal was launched in 2019. Its commitment is to achieving the ambitious goal of net neutrality by 2050.
After this, the efforts were fast-tracked. CEAP (Circular Economy Action Plan) was introduced in 2020, and the DPP was proposed for the first time.
ESPR (Ecodesign for Sustainable Products Regulation) was proposed as a legal framework to enforce and monitor the DPP. This was needed as the Circular Economy applies not just to Electronic products but to everything in the EU market.
DPP by ESPR solved other problems which previous efforts could not (at least not in this efficient manner), including
Unified Framework - This encapsulates the whole lifecycle and all the stakeholders involved in the product.
Digital Interoperability - Between all the stakeholders, including the ones in the supply chain.
Role-based access—This ensures everyone involved gets access to the information, especially the customer, who can scan the QR code and easily access the relevant data.
What is DPP (Digital Product Passport)?
A DPP (Digital Product Passport) is a digital record that contains information about the product's lifecycle, raw materials, essential timelines, such as expiry and reusability, and other factors, such as its contents after expiry.
The goal is to achieve the following.
Transparency
Scanning a QR code allows the essential data (which changes depending on the user's role) to be accessed without hassle. This gives immediate insights about the product without worrying about the authenticity of the content.
Performance
DPP contains information about the attributes of products which can quantify the performance of products like
Energy efficiency (for electronic products), i.e., how much energy they should consume, etc., allows customers to make informed decisions reliably.
Raw material: These attributes mention the exact ingredients of the product. For example, a battery might use rare earth materials. This information is helpful for the following section.
Lifecycle: These attributes define the expected lifespan of the product, and when used with raw material data, they can be used to efficiently reuse the raw materials when the product reaches its end-of-life.
Sustainability
These fields help track and reduce the negative environmental impact. The Ecodesign for Sustainable Products Regulation (ESPR) by the European Union played a crucial role in focusing on this aspect of DPP.
Circularity
An essential aspect of The Green Growth Project, Circularity focuses on a product's whole journey, from raw material extraction to its post-end-of-life disposal and reuse. This ensures minimum environmental damage and maximum usage of the raw materials used.
More information
Construction industry in Europe
It's no secret that the construction sector is significantly large. It contributes 9% to 10% of Europe's GDP. Any change to regulation will have a significant impact on business, and stakeholders need to make an effort to comply with EU regulations for DPP for the construction industry.
What is DPP for the construction Industry?
This is an industry-specific extension of the EU's broader Digital Product Passport framework governed by ESPR (discussed later; bear with us now). It has tailored attributes catering to the construction industry's stakeholders.
CPR governs DPP for the Construction Industry as this industry cuts across multiple sector verticals, as depicted in the following diagram
What is Ecodesign for Sustainable Products Regulation (ESPR)
It is the European Commission's dedicated body that focuses on DPP. ESPR extends the EU's generic Ecodesign rule, but this time, it makes it a formal protocol, which is eventually called DPP. ESPR makes all the proposals and amendments to the DPP.
ESPR is set to cover every relevant sector in the EU and define an actionable plan for DPP in the future, with some of the most pertinent sectors attended first. For example, DPP for batteries is already in the final phases of defining the DPP rules and compliances.
The following timeline diagram shows the important dates.
You can read more about ESPR on its official EU page.
What is New Construction Products Regulation (CPR) – Sector-Specific DPP for Building Materials
Broad sectors like construction need a complex route because of the broad spectrum of products the industry caters to. Let's consider Steel, Iron, and Paints. These all fall into the construction industry, but they are different genres of products, which will likely each have their tailor-made DPP rules. To cater to this, we have CPR(Construction Products Regulation).
NOTE—The DPP for all construction products is decided and enforced by CPR, not ESPR. This is important to note as the rules for DPP in the construction sector are set and governed by CPR. CPR considers DPP rules from ESPR as its basis but adds its twist to cater to the construction industry specifically, for example, considering interoperability with Building Information Modelling (BIM) tools.
Important dates are noted in the following timeline diagram.
Following are the reads about CPR
How are ESPR and CPR related?
DPP (for the construction industry) by CPR is a concrete version of base DPP by ESPR. The following diagram helps us understand this.
CPR mandates DPP for the Construction industry. It contains the basic attributes of DPP from ESPR and adds industry-specific fields (e.g., BIM tools), as mentioned above in our conversation.
How does DPP for Construction products work?
Product Identification
Each product is assigned a unique identifier across the DPP framework to ensure it gets uniquely identified. It can be carried as a QR code on the physical product, providing easy access to the DPP.
DPP Structure
Identifiers: Three main identifiers are mandated by CPR:
UPI (Unique Product Identifier) - Uniquely identifies precisely one product without ambiguity.
Unique Operator Identifier - Uniquely identifies the manufacturer or importer.
Unique Facility Identifier - Uniquely identifies the facility where the product has been manufactured.
Other Data Fields
Below are some essential field sets that are almost certain to make it to the DPP. Please note that the fields are not finalized yet, so expect changes to this list eventually. Also, it is worth noting that each point in the following list is a set of fields.
Material and Component information
Sustainability Features
Performance Features
Life Cycle information
Compliance and Certifications
Safety information
Supply chain data
Maintenance and repair information
Who are the stakeholders, and who can access what?
There are three types of stakeholders involved. Their access is discussed in the following section.
1. Regulatory Authorities: EU/ ESPR/ CPR
These stakeholders have got
No burden of creating and maintaining the DPP data
Maximum read (and no write) access. Expecting role-based access in future fine-tuned mandates from CPR
2. economic operators: Manufacturers and Importers.
These stakeholders have got
Accountable for the creation and maintenance of DPP data and its correctness.
Maximum read and write access.
3. Consumers
These stakeholders have got
No burden of creating and maintaining the DPP data
Limited read (and no write) access. Only fields relevant to the user are available. E.g. lifecycle, ingredients, etc.
Impact on the businesses/What should I know if I am in the construction business
The responsibility of implementing and catering for the DPP system is supposed to be done by economic operators, i.e. manufacturers (or importers in case the manufacturer is outside of the EU)
There are many steps involved in developing the DPP system.
Identification of attributes needed -
This has to comply entirely with the ever-evolving guidelines of CPR on DPP.
Information Gathering
Available fields—This is probably the easiest information-gathering effort: identifying and adding the already available fields in the DPP system.
Non Available fields - Perhaps the more difficult part is identifying the missing fields and then gathering that information from relevant sources (e.g. asking about raw material data from the upstream supplier)
Creating infrastructure
DPP database—Create a compliant database to store all the DPP data. CPR security mandates, such as secure communication and data encryption, must be honoured.
Role-based authorization for different types of stakeholders to access data, as discussed in the previous section
Amending existing technical stack
The construction industry probably uses tools like BIM (Building Information Modeling) based on the OpenBIM protocol; how they are used, if not the software itself, needs updating.
The Timelines overview
Following is a detailed timeline for the construction industry
DPP for different sectors and industries will be defined and mandated at different timelines. Batteries come first, with a deadline of 18 February 2026.
For Manufacturing Industry Products, this date is (targeted to be) 8 January 2027
Challenges
Country-specific laws
As this DPP effort is Europe-wide, the country where the product in question is being placed also has a role to play, and any country-specific divergence can make the process easier for economic operators. For example, countries must update their laws and legislation around products to comply with the EU's DPP concept. However, most European countries do have a "Mutual Recognition Agreement" (MRA) in place, which (at least in theory) should neutralize this problem.
Potential Redundancy
Some sectors in some industries already track products and their attributes in a fashion similar to DPP. This will be a redundant effort for them, meaning they will need to adapt to the DPP way of CPR by either giving up on their existing system or modifying theirs as per DPP.
Transparency
Standardization and Interoperability
Making the data uniform and machine-readable will be challenging, especially since multiple countries have different primary languages. This can make DPP compliance a big task in itself. Also, the Construction industry cuts across various sectors (like Cement, Steel, Wood panels, etc.), making Standardisation even more complex.
Opportunities and Benefits
Customer Trust, thanks to Transparency
With DPP-compliant information available to customers, economic operators no longer need to convince them about the authenticity and correctness of information about the product, which positively influences them.
Streamlined Compliance
While compliance is initially complicated, once the infrastructure is in place, it will make the manufacturer's life easy as it will be very efficient, specifically when talking about intra-country (or EU-wide) compliance.
Access to broader market
Compliance with the DPP automatically makes the manufacturers eligible to sell to the wider European market, not just the country of origin.
Cost Saving
As counterintuitive as it may seem, the DPP can help manufacturers save money if the data is analyzed and used correctly within the organization to gain insights and optimize waste reduction and product reuse.
What is industry talking about/ Industry Response and Guidance
Realizing the impact of DPP, the industry groups are already not just keeping an eye on but also engaging and discussing the ideas with the regulation agencies. These groups include the following
European Steel Association (EUROFER)
CEMBUREAU (cement)
Industry groups are also publishing papers and deploying pilot solutions for the same.
FAQs
What is the EU Digital Product Passport Regulation?
Ans: The EU digital product passport regulation mandates that products in the EU have a digital record, i.e. DPP, which is supposed to contain information about their lifecycle, from raw materials to disposal, to enhance transparency, sustainability, and circularity.
Who is an Economic Operator?
Ans: The manufacturer (or the importer if the manufacturer is from a country outside the EU) is referred to as the economic operator.
