One question that remains on top of many's minds is, "What are the data requirements in the Digital Product Passport (DPP)?" While we do not have the final data requirements yet, the working group from the Trace4Value DPP prototype project, which included TrusTrace, GS1 Sweden, Kappahl and Marimekko among others, have strong indications of what they will be.
DPP is a critical enabler for ensuring that the most relevant product data for circular value creation across value chains is readily available, and has three primary components:
DPPs serve as the digital identity of each product, encompassing details about the brand responsible for its creation, the manufacturing process, the materials used, care instructions, and its potential for circularity - from repair and reuse to disassembly for recycling. Additionally, the DPP will contain information on environmental impact and compliance with chemical regulations.
During the Trave4Value project, 125 different data points were determined. While not every single data point is new, meaning that brands are already collecting some them as part of existing requirements or standards like the EU REACH list and Ecodesign. These are simply being integrated into the DPP, therefore a lot of the likely data points have been identified with high confidence. Others points will be legislated through the anticipated Delegated Acts.
Experts from the working group confirmed during a live panel on the DPP that the main discourse is not on the data points at this point. Instead, the ongoing debate is now around the DPP system and technical requirements.
According to ESPR guidelines, each product must possess a distinct identifier known as a persistent unique product identifier. This unique identifier must also be permanently attached to the garment as it will contain the data needed to activate its circularity. It is typically a serialized Global Trade Identification Number (GTIN) in accordance with the GS1 Standard, and ensuring comprehensive traceability. Irregardless of the carrier, it must be machine readable and in the Unlocking DPP playbook we have shared several formats, although there is high confidence that a QR Code could be defined as the main carrier.
The DPP framework states that data can be made available via a data carrier but there is no mention of blockchain as a requirement for managing the data integrity. Instead, when it comes to data availability, the ongoing discussions are around whether there is need for a centralized backup solution, an EU registry, to ensure availability.
ESPR outlines the access privileges for each stakeholder when it comes to data accessibility. While consumers are limited to accessing public data, regulatory authorities have the ability to delve deeper into the Digital Product Passport information. These access rights are anticipated to be further elaborated in the upcoming Delegated Acts, scheduled to be finalized by the conclusion of 2025.
In contrast to the clear direction for DPP data requirements, the technical DPP system requirements (comprising the system architecture and the unique identifier) are not as well defined. There are also a lot of questions yet to be answered about data security and management once implemented.
At a local level, companies are collaborating together in local working groups like the Trace4Value project. This allows for field testing of what works or does not work when it comes to data requirements for Digital Product Passports. The active experimenting helps the parties involved in shaping policy understand the reality and obstacles for data gathering and management, for example determining the feasibility of the 125 data points implemented in the project's DPP prototypes.
Curious to get into the data and details? You can view the report with the data protocol here: https://trustrace.com/downloads/digital-product-passport-data-protocol