Sustainable Plastics - September/October 2022 - 13

material matters
weighs but 780gr. Bingo! You've
found your machine.
Advancing Circularity
On 30 March 2022, the European
Commission presented a
package of proposals that are
part of the European Green
Deal. At the heart of the package
is a proposal for a Regulation
on Ecodesign for Sustainable
Products. Its goal is to
make sustainable products the
norm in the EU, boost circular
business models and empower
consumers in their decisions.
In the future, physical goods
across almost all product categories
will be subject to this
regulation, with only medicinal,
feed and food products exempted.
This means that, among other
things, any company selling
a product in the EU market will
be required to supply information
about the product and its
constituent components. And,
although it is an EU regulation
that applies strictly speaking
only in the EU, it will inevitably
also have a knock-on effect on
global trade.
The Ecodesign for Sustainable
Products Regulation
(ESPR) is an ambitious one and
it will affect many stakeholders
along the entire value chain of
product creation. Although not
yet implemented, it is on its way.
A key regulatory element
in the regulation is the Digital
Product Passport (DPP). Such a
passport will enable products to
be tagged, identified and linked
to data relevant to their circularity
and sustainability. In the EU,
digital product passports are
envisaged to become the norm
for all products regulated under
the ESPR.
Full Transparency
What kind of information should
a digital product passport contain?
Depending on the product
in question, it could include information
on the raw materials,
energy usage, recycled content,
presence of toxins, durability,
reparability (including a reparability
score), spare part availability
and recyclability.
Pioneering this approach to
environmental sustainability
data may also pave the way for
a wider, voluntary data sharing
Efrat Friedland
branches. In June 2022, they
published a position paper laying
out the principles they welcome
and support as well as
their concerns.
Orgalim supports the DPP's
that goes beyond the products
and requirements regulated under
the ESPR. Moreover, product
passports could also serve
to provide information on other
sustainability aspects- aspects
such as forced labour, deforestation,
or waste shipment, to
name but a few.
As you can imagine, however,
the average size of a nutrition
facts label will hardly be sufficient
for all this information. Not
to mention the fact, that a car
is made up of more ingredients
than an energy bar.
This is where digitalisation
comes into play. By creating a
so-called 'digital twin' for every
product, it becomes possible to
store the entire documentation of
a product online and in the cloud.
A quick google search for
" digital product passport tool " ,
" supply chain traceability tool "
or " blockchain digital passport "
turns up a generous selection
of well-known and less wellknown
software companies that
already are active in providing
solutions for the easy and safe
registration of such information.
The trendsetters
What industries will be the first to
adopt this approach - or perhaps
be forced to supply such digital
passports? Surprisingly enough,
although the automotive industry
is one of the more complex in
terms of supply chains, European
electric vehicle manufacturers
have been promoting such a
regulation since 2020. Focusing,
to begin with, on batteries. This
is mainly driven by their wish
to differentiate themselves from
the traditional automotive industry
and to gain environmental
advantages. Also, not unimportantly,
their supply chains have
only relatively recently been assembled
and are therefore easy
to track. The textile and toy industries
are likely to be the next
to follow.
No less complex than the
automotive industry is the construction
industry and here, too,
steps are being taken. Madaster
is an online registry for materials
and products for the built environment.
On this digital platform,
buildings are registered, including
the materials and products
used in their construction. Their
registration and documentation
facilitate their reuse in a circular
economy, for the purpose of
eliminating waste. The system
automatically generates secure,
web-based passports containing
all the information about the
quality, origins and location of
materials and products used in
the building.
Too good to be true?
In other words, the digital tools
are out there, the case studies
are available, too. The European
Commission is about to set
the regulation in stone and the
road to a circular economy in
the industry would appear to
be almost fully paved. However,
the missing part of the picture
is the industry, and some
of its members are not happy
about this package of proposals.
Take Orgalim, for example,
the EU organisation representing
Europe's technology industries
- the continent's largest
manufacturing sector. Its members
comprise some 770,000
innovative companies active
in the mechanical engineering,
electrical engineering and electronics,
and metal technology
contribution to the circular
economy, in terms of ensuring
effective enforcement and
promoting a functional internal
market. Their main concerns
are the protection of the confidential
business data, as well
as a possible disproportionate
burden on the industry. They
have put forward a number of
recommendations in which
they call for, in the first place,
the principle of data minimisation
- in other words, providing
as much data as needed, as little
data as possible. In addition,
according to the association,
access to information should
be allowed on a need-to-know
basis only, requirements must
be measurable and enforceable
and there should be no double
regulation for chemicals (which
already exists).
If we look back at the Nutrition
Facts Label, the US regulator of
food labelling faced a similar
challenge when it came to genetically
modified organisms
(GMOs). The food industry was
against having a physical label
marking GMOs on the product.
They therefore created a digital
label stating the presence of
GMOs. This is still the practice
today, with mandatory GMO disclosure
in the U.S. achieved via a
QR code printed on the product
itself that consumers can scan.
To conclude, the benefits of
the Digital Product Passport
are multiple. Such a passport
makes it easier for consumers
to make informed decisions
and for authorities to enforce
regulations and maintain surveillance.
It makes it easier for
businesses to access information
that can improve their environmental
performance.
The availability of and access
to reliable information are crucial
for the circular economy. The
implementation of the Digital
Product Passport offers an opportunity
to create traceability
and transparency throughout the
value chain. This, in my opinion, is
a valid enough reason to push it
forward, creating a standardised
solution that will be accepted by
most, if not all, stakeholders.
September/October 2022
13
Sustainable Plastics - September/October 2022

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