It is not surprising that climate change is becoming a growing weight on society, with sustainability needing to take priority if we want to protect the future of our planet. To put this into context, over the last few years, the UK alone has been responsible for 1.6 million tons of electronic waste, and it is known to be one of the largest e-waste producers worldwide.
Although these figures are slowly decreasing, sustainability must become a growing business imperative if we want to seriously change the tide. For businesses to truly thrive, more sustainable practices are essential to success in the modern consumer climate.
Beyond both consumers and businesses, governments are also being seen to take note of the importance of increased sustainability and implementing a range of measures to help foster a circular economy. In particular, as part of the EU’s Ecodesign for Sustainable Products Regulation (ESPR) and its recent Energy Labelling Working Plan announcement, the EU aims to ensure tech companies that place products in the EU marketplace start implementing processes to tackle sustainability first hand.
Digital Product Passport and Circularity Specialist at Protokol.
The regulatory reasoning: The EU’s ESPR and Working Plan
Under its Circular Economy Action Plan (CEAP), the EU has led a series of efforts aimed at pushing businesses toward greater sustainability and circularity. A clear example of this commitment is the ESPR, which came into effect last summer and underscores the European Commission’s drive to build a more circular, resource-efficient economy.
For context, the ESPR aims to boost circularity and the practices that contribute to sustainability by creating a framework that “aims to make sustainable products the norm on the EU market.” In layman’s terms, it focuses on the production of items that last longer, use energy and resources more efficiently, are easier to repair and recycle, contain fewer substances of concern and include more recycled content.
The circularity regulation is set to apply to select product groups, including those in the electronics and textiles space, and will apply to all businesses that place products within these groups on the EU marketplace, regardless of where they were produced.
As part of this, businesses will need to work towards the implementation of Digital Product Passports (DPPs) – a mandatory requirement for products that fit within the identified product categories.
As the ESPR’s first Working Plan was published at the end of April, a document officially listing the sectors due to be prioritized by the regulation, it is more pressing than ever for technology companies to begin their ESPR compliance journey now.
As the Working Plan provides a timeline for the delegated acts – a set of requirements concerning each product group – to be announced , compliance urgency is increasing at speed. Moreover, with the Working Plan outlining a range of upcoming horizontal requirements, such as repairability for consumer electronics and increased use of recycled content, the technology industry has been listed as a key priority.
In simple terms, the Working Plan aims to focus on the ESPR’s ability to have positive environmental impacts, its capacity to deliver, and the need to simplify regulations.
This update in legislation, and its focus on the timeline for the delegated acts to be announced, is only another reminder that the compliance clock is ticking for technology companies across the world that sell in the EU marketplace.
With the timelines for the delegated acts now established—some taking effect as early as 2026 for sectors like steel – businesses face significant changes in the near future. Companies that delay action risk not only non-compliance but also losing their competitive edge.
Where do DPPs fit in? The mandate and fostering eco-products
To unpack DPPs – a key component of the compliance exercise – they largely act as a digital record of a physical product, securely keeping track of information across its lifecycle. This can include anything from the material used in its production, the environmental impact of its manufacturing, a record of its authenticity, and guidance for end-of-life handling. In most circumstances, this data will be accessible via a data carrier like a QR code or barcode affixed to a product and accessible by scanning with a device such as a smartphone.
DPPs are set to play a key role in advancing the ESPR’s circularity ambitions by offering greater visibility into a product’s entire lifecycle. By embedding DPPs into products, the regulation encourages everyone who interacts with them, from manufacturers to end-users, to adopt more sustainable practices and embrace circular thinking.
For consumers, DPPs provide the information needed to make environmentally conscious purchasing decisions and dispose of products responsibly at end of life. For businesses, this level of transparency opens up opportunities to enhance sustainability across supply chains, from sourcing materials to refining internal processes.
DPPs also prove beneficial to tech industry businesses when considering notions of brand engagement and customer loyalty. For example, they could help businesses to prove the sustainability credentials of their products to the end consumer and can help to avoid accusations of greenwashing.
By potentially even verifying authenticity and keeping a history of any repairs made to a product, technology firms could even utilize the information in DPPs to facilitate take back or resale schemes, encouraging users to recycle their products, turning them back into usable products to be resold – another effort towards the circular economy.
Action point one: Data and DPP solution strategies
As the ESPR’s Working Plan has just been released, it is very easy for businesses to feel overwhelmed by the upcoming regulation and its DPP mandate. In particular, with the Working Plan establishing the horizontal requirements and its focus on product repairability and recyclability, the technology sector must begin considering its DPP compliance journey now to ensure the products they create meet sustainability standards.
As a first step, businesses should assign an employee or team to be at the forefront of upcoming compliance efforts. By ensuring that an employee or group of employees is staying updated on legislation, businesses can ensure they remain aware of specific industry requirements coming down the pipeline.
As part of this, it would be advisable to reach out to a DPP advisor and gain a deeper understanding of the mandate’s industry-specific impact. By doing so, companies can carve out a coherent and bespoke strategy accordingly.
To stay ahead of the ESPR, businesses should start by mapping where critical product data resides – both within their own operations and throughout their supply chains. It’s also essential to evaluate which partners are best equipped to support the rollout of DPPs. Once a solution is in place, piloting becomes the logical next step.
Running a pilot allows companies to test implementation in real-world conditions, identify process gaps, and gather valuable data to better estimate the scale and timing of a full rollout. With this groundwork laid, businesses will be well-positioned to accelerate their efforts as soon as the delegated acts come into effect.
For all tech companies selling into the EU marketplace, the ESPR’s forthcoming DPP mandate represents a range of challenges and opportunities for the industry. As the Working Plan’s recent publication only heightens the need for DPP compliance, this moment represents a critical chance to advance a circular economy.
As companies are faced with an opportunity to advance their sustainability credentials (and subsequent business success), the way they choose to tackle this legislation will determine whether they merely meet compliance standards or accelerate as sustainable brands of the future.
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