The Digital Product Passport under the EU Ecodesign Regulation 2024: Empowerment of the Customer-Consumer on the Road to Sustainability in a Circular Economy or Information Overload?

Abstract

The European Commission has established mandatory ecodesign requirements for products and services introduced into the internal market under the new Ecodesign Regulation from 2024 (ESPR) in order to support the development of a circular economy and increase the EU’s competitiveness. The measures encompass product parameters and information requirements. Here, the newly established Digital Product Passport (DPP) will play a central role, complemented by labels and other information sources. This paper investigates the information requirements, the DPP, and labels in order to discover whether these measures will realise the ESPR’s aim of improving product traceability and of positioning consumers to make sustainable choices and ultimately promote sustainability and a circular economy. The DPP’s efficiency as an information tool and its interaction with labels, as well as the change to the consumer’s position in terms of their safety and their rights will be considered. While the ESPR’s implementation and product-group specific regulation is still underway, the DPP looks to become a comprehensive data provision tool that will place relevant and easily comprehensible product information at the customer’s fingertips. Aspects from the product’s whole lifecycle will be covered, from origin and materials used, over resource consumption during production and when in use, to contained substances of concern, as well as instructions for installing, using, maintaining, and disposing of the product. This information is also relevant for other economic operators like repairers, refurbishers, and waste disposers. For the economic actor burdened with the creation and maintenance of the DPP, often the manufacturer, the tool brings advantages like enhancing buyer trust and product differentiation. The transparency of product parameters and the ensuing market competition will foster incentives for product development and thus increase the sustainability of offered products. The DPP has limitations, like its accessibility for vulnerable consumers and its scope, and important opportunities might be missed if these are not addressed. Despite this, the information requirements and in particular the DPP appear to be measures that will support the European Green Deal, as well as the New Circular Economy Action Plan and the New Consumer Agenda and enhance the internal market’s sustainability and circularity.