Photo of Sheila MillarPhoto of Ales Bartl

On March 30, 2022, the European Commission (EC) unveiled a proposal for a framework eco-design regulation aimed at creating a policy framework for sustainable products. Among the tools proposed by the EC is the EU Digital Product Passport (DPP), a product-specific data set that would apply nearly to all non-food products sold in the EU and would require disclosure of a vast array of information, much of it currently deemed confidential business information. Through DPPs, both competent authorities and users across the supply chain will have access to information including origin, materials, and sustainability and recyclability, via a scannable QR code. DPPs are intended to promote circularity and economic growth, help consumers make sustainable choices, and improve enforcement. If adopted as envisaged in 2024, the DPP framework would likely enter into force in 2027. In addition to environmental and product safety considerations, intellectual property rights, usefulness of the data, privacy and security are all important issues for affected companies to consider.

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