Deliverable 9.6: Policy Briefs Report Covering Second Four White Papers for Policy Dissemination

This project has received funding from the European Union’s H2020 Programme under Grant Agreement No. 958448 WP9. Regulations and Standardisations Task 9.6 Policy Recommendations in the Context of the EU Green Deal Deliverable 9.6 Policy Briefs Report Covering Second Four White Papers for Policy Dissemination Ref. Ares(2025)3402553 - 28/04/2025 2 DISCLAIMER The opinion stated in this report reflects the opinion of the authors and not the opinion of the European Commission. All intellectual property rights are owned by CIRCTHREAD consortium members and are protected by the applicable laws. Reproduction is not authorised without prior written agreement. The commercial use of any information contained in this document may require a license from the owner of that information. ACKNOWLEDGEMENT This project has received funding from the European Union’s Horizon 2020 research and innovation programme under grant agreement Nº 958448. This task was led by dss+ who coordinated the related policy monitoring and development of the policy briefs and conducted the main authoring of the briefs alongside ECOS who authored two of the four briefs alongside dss+. Contributions were made from partners in line with their substantial expertise in the subjects discussed, namely from: Eco-wise, UNI, Altroconsumo, Euroconsumer, OCU and DECO PROTeste. 3 Project Data Project Acronym CircThread Project Title Building the Digital Thread for Circular Economy Product, Resource & Service Management Grant Agreement number 958448 Call identifier H2020-LCCI-2020-EASME-twostage Topic identifier CE-SC5-31-2020 Develop, implement and assess a circular economy-oriented product information management system for complex products from cradle to cradle Funding Scheme IA - Innovation action Project duration 48 months (From 1 June 2021) Coordinator FUNDACION CARTIF Website https:// circthread.eu Deliverable Document Sheet Deliverable No. 9.6 Deliverable title Policy Briefs Report Covering Second Four White Papers For Policy Dissemination Description Linked to T9.6. Provides the Policy briefs report covering second four white papers for policy dissemination for the CircThread projects including as outcomes: an updated summary of the EU policy framework for Circular Economy and Sustainable Products in the context of the EU Green Deal with legislation developed to project M43, a summary of the selected four white paper policy brief themes, and a summary of the developed policy briefs. Based on the recommendations in the policy briefs in relation to a Circular Economy in Europe the deliverable is marked as contributing to policy issues/recommendations. WP No. WP9 Related task T9.6 – Policy Recommendations in the Context of the EU Green Deal Lead Beneficiary 18 - UNI Author(s) Amba Concheso (dss+), Radha Daniel (dss+), Margaux Le Gallou (ECOS), Contributor(s) Rembrandt Koppelaar (ECOW), Cristina Dimaria (UNI), Claudio Perissinotti (UNI), Sara Strippoli (Altrosonsumo), Luisa Crisigiovanni (Euroconsumers), Isabel Oliveira (DECO PROTeste), Javier Pablo Garcia (OCU), Susana Fernandez (OCU), Stefano Casiraghi (Altroconsumo), Amaya Apesteguia (OCU) Type R Dissemination L. Public Language English – GB Due Date 31/03/2025 Submission Date 28/04/2025 4 Version Action Owner Date V.0.1 First version of 4 draft policy papers dss+ & ECOS 21/01/2025 V.0.2 Review & copy-edit of 4 draft policy papers ECOW / ECOS 08/02/2025 V.0.3 Review & copy-edit of 4 draft policy papers UNI/Altroconsumo/DECO PROTeste)/Euroconsumers/OCU 04/03/2025 V.0.4 Final version of 4 draft policy papers dss+ & ECOS 10/03/2025 V.0.5 First version of deliverable 9.6 dss+ 18/03/2025 V.0.6 Review of deliverable 9.6 ECOW 28/03/2025 V.1.0 Final deliverable 9.6 dss+ 18/04/2025 V.1.1 Submitted deliverable 9.6 incl. last check dss+ / CARTIF 28/04/2025 5 TABLE OF CONTENTS Executive Summary ............................................................................................................................ 7 Introduction .......................................................................................................................................... 8 Policy Brief #1: How Digital Product Passports can contribute to science-based circular economy targets .............................................................................................................. 10 1.1 Introduction ............................................................................................................................. 10 1.2 To truly deliver environmental benefits, the circular economy must integrate actions across four pillars ........................................................................................................................ 11 1.3 Current EU circular economy policies lack comprehensive coverage across all four pillars ..................................................................................................................................................... 12 1.4 From opportunity to direction: the need for Circular Economy targets............. 13 1.5 The DPP as a tool to build the data foundation of a science-based circular economy policy ............................................................................................................................................ 16 1.6 Recommendations ................................................................................................................. 19 Policy Brief #2: Ensuring chemical traceability with the Digital Product Passport .................................................................................................................................................................. 21 2.1. Introduction ............................................................................................................................. 21 2.2. State of play of chemical traceability .............................................................................. 22 2.2.1. Defining chemical traceability .................................................................................... 22 2.2.2. Current EU traceability tools fail to trace back chemicals present in products 23 2.3. ESPR: a new dawn for chemical traceability? ............................................................... 25 2.3.1. Introduction to the ESPR .............................................................................................. 25 2.3.2. Chemicals in ESPR ........................................................................................................... 25 2.3.3. Information requirements............................................................................................ 26 2.3.4. Confidentiality Concerns ............................................................................................. 26 2.4. The DPP: solving database issues..................................................................................... 27 2.4.1. Introduction to the DPP ................................................................................................ 27 2.4.2. Interplay between the DPP and existing databases ........................................... 28 2.5. How to ensure the DPP increases traceability ............................................................ 29 2.5.1. Learnings from CircThread .......................................................................................... 29 2.5.2. Addressing critical raw materials from e-waste ................................................... 30 2.5.3. Ambitious chemical traceability, cost of traceability, and access................... 30 2.6. Recommendations and conclusion .................................................................................. 31 Policy Brief #3: Product lifecycle information for consumers ...................................... 33 3.1. Contents Overview ............................................................................................................... 33 3.2. Information flow from viewpoint of consumer ............................................................ 33 3.3. Consumer drivers for accessing or sharing data ......................................................... 35 3.3.1. Key consumer trends regarding repair .................................................................... 36 3.3.2. Key barriers for consumers to share use-phase data ......................................... 37 3.4. A DPP can facilitate an ongoing communicative relationship with consumers 38 6 3.5. A DPP can facilitate an ongoing communicative relationship with consumers 39 3.6. Recommendations for a DPP to facilitate the sharing of use-phase consumer data 41 Policy Brief #4: Circular applications data space................................................................ 44 4.1. Contents Overview ............................................................................................................... 44 4.2. EU Policy Context .................................................................................................................. 45 4.3. Key applications and benefits of EU Data Spaces in the Circular Economy ...... 46 4.4. Key requirements for implementation of Circular Applications Data Spaces .. 49 4.5. Conclusions and Recommendations for Circular Applications Data Space ...... 52 Conclusions ........................................................................................................................................ 55 Policy Brief 1: How digital product passports can contribute to science based circular economy targets .......................................................................................................................................... 55 Policy Brief 2: Ensuring chemical traceability with the Digital Product Passport ............... 56 Policy Brief 3: Product lifecycle information for consumers ....................................................... 58 Policy Brief 4: Circular Applications for Data Spaces .................................................................... 59 Next steps ...................................................................................................................................................... 61 Annex .................................................................................................................................................... 62 1.1. Annexes to Policy Brief #2 on Ensuring chemical traceability with the Digital Product Passport ........................................................................................................................................ 62 1.2. Annexes to Policy Brief #3 on Product Lifecycle Information Management for Consumers ................................................................................................................................................ 63 1.2.1. Data results from WP3.2 survey ................................................................................ 63 1.2.2. Workshop discussion held by dss+ and Eco-wise with consumer associations Altroconsumo, OCU and DECO PROTeste at the CircThread GA in Porto, Portugal, June 2024 ............................................................................................................................................. 64 1.2.3. Durability Index Overview ........................................................................................... 64 1.2.4. Possible terminology that is more consumer-friendly ....................................... 65 1.3. Annex to Policy Brief #4 on Circular Applications Data Spaces ............................ 65 7 EXECUTIVE SUMMARY CircThread seeks to make appliances like boilers and washing machines sustainable. To achieve this, we want to swiftly increase appliance lifespan, repairability and reuse. And ensure that products are properly recycled when they are no longer repairable. We are working on this challenge with more than 30 organisations, thanks to grant funding from the European Union under the H2020 programme. To solve this challenge, we will put in the hands of all actors a software platform for sharing critical information about appliances and devices. Information shared between product designers, manufacturers, retailers, citizens, repairers, and recyclers. Radically improving our ability to make better lifespan improvement, reuse and recycling decisions. Helping you and others with circularity decision making at all stages of a product’s life cycle. This deliverable, a culmination of the work conducted under T9.6, includes a collection of four policy briefs aimed at providing critical insights and recommendations regarding the development of the EU’s Digital Product Passport (DPP). The DPP, a new universal product information portal, is shaping as a new instrument and innovation in the context of the EU Green Deal's efforts, to promote sustainability and environmental responsibility. In a rapidly evolving landscape driven by a surge in digitalisation and increasing environmental awareness, the DPP emerges as a tool for enhancing sustainability across industries. The key objective of these second set of policy briefs is to address the multifaceted challenges and opportunities surrounding the DPP system and put forth recommendations for EU policymakers when designing the related legislation. Building on the first four papers authored for deliverable 9.5, these policy briefs delve into additional aspects of DPP implementation and its potential impact on consumers, data systems, use of chemicals and setting of circular economy targets. The four briefs cover: • The DPP in relation to circular economy targets • The DPP in relation to ensuring chemical traceability • The DPP in relation to the product lifecycle information for consumers • and the DPP in relation to circular applications data Spaces The intended audience of this report is at first level the European Commission, for whom a set of policy recommendations have been developed to inform the policymaking process surrounding the DPP. It serves as a resource to guide and inspire legislative developments, to ensure the DPP can play a transformative role in advancing the EU’s sustainability goals. This report will not only serve the internal needs of the EU Commission but will also be published externally. Its reach is thus expected to extend to policymakers, regulatory bodies, business leaders, industry professionals, environmental stakeholders, and the broader public who share a collective interest in fostering a more sustainable and circular economy within the European Union. 8 INTRODUCTION Context This deliverable is linked to the work conducted as part of T9.6 ‘Policy Recommendations in the Context of the EU Green Deal’ within the broader WP9 of Regulations and Standardisation. T9.6. has consisted of mapping of CircThread solution against the EU Green Deal main themes, particularly to initiatives and planned activities clustered under Climate Ambition, Industrial Strategy, Mainstreaming Sustainability, EU as Global Leader and Climate Pact main areas. The task builds upon the project results (T7.5) and the identified regulatory needs (T9.1/T9.5) and feedback (T9.2) to provide for a set of concrete policy recommendations. The CircThread findings and knowledge acquiesced under this task have been synthetised into a set of policy recommendations comprised in this second set of four policy briefs under D9.6. Each chapter within this report corresponds to one of the four policy briefs, exploring the DPP in relation to specific topics: • The first policy brief explores the type and scope of Circular Economy Targets that need to be set to actively reduce the global overuse of resources and how the DPP can facilitate meeting such targets • The second policy brief comprehensively examines the use of chemicals in products and how the DPP can encourage their traceability • The third policy brief delves into the challenge of encouraging consumers to use the DPP to share information about their use of products to encourage repair and reuse • The fourth policy brief takes a deep dive into the circular applications data space and data flow/access via the DPP to maximise circular economy uses These four policy briefs have been based on the CircThread findings to present in the project. In the pursuit of the most robust and effective policy recommendations, our team has actively engaged with key stakeholders from industry, academia, and policy domains. This approach has allowed us to deeply comprehend the multifaceted themes related to the development of the Digital Product Passport (DPP) and its implications for the European Green Deal. Audience This report is directed to the European Commission, with the intentions of putting forth policy recommendations for the development of the DPP in the EU, grounded in the knowledge and insights acquiesced from the CircThread project’s findings. In addition, each policy brief will also be shared externally to the general public with the intention of promulgating the findings and policy recommendations with multi-sectoral stakeholders to add valuable insights in relation to the DPP’s development in Europe. 9 Definitions / Abbreviations • DPP (Digital Product Passport): A digital record containing detailed information about a product, its lifecycle, and sustainability characteristics. • Extended Producer Responsibility (EPR): A policy approach where manufacturers are responsible for a product's end-of-life disposal. • ESPR: Ecodesign for Sustainable Products Regulation • CEAP: Circular Economy Action Plan • CRMs: Critical Raw Materials. • WEEE: Waste Electrical and Electronic Equipment. • EEE: Electrical and Electronic Equipment. • Refurbisher: reseller that acquires faulty products with the intention of bringing it to its original conditions and reselling it. Refurbishing is any functional or aesthetical maintenance or repair of an item to restore to original, upgraded, or other predetermined form and functionality. • DGA: Data Governance Act Contributions of partners This task was led by dss+ who coordinated the related policy monitoring and development of the policy briefs and conducted the main authoring of the briefs alongside ECOS who authored two of the four briefs alongside dss+. Contributions were made from partners in line with their substantial expertise in the subjects discussed, namely from: Eco-wise, UNI, Altroconsumo, Euroconsumers, OCU and DECO PROTeste. 16 This target should be seen as an initial target. The EU should commission further research, collaborating with the International Resources Panel and other relevant organisations to refine existing methodologies and develop science-based targets to reduce the EU material footprint. Every policy action should be selected based on its potential to contribute to these targets – this will ensure a coordinated approach to achieving the necessary material footprint and GHG emissions reductions. Targets should focus on particular material streams and/or sectors and include monitoring assessments and evaluation of performance to allow for adjustments as needed. 30 The European Environment Agency proposes a six-step process for integrating circular economy measures into climate reporting, which should be considered to ensure comprehensive policy alignment. 31 Binding, quantified targets to reduce the EU’s material and climate footprints will ensure that the next generation of circular economy policies are chosen for their high potential to transition the EU into a circular economy and meet its material and climate targets. 1.5 The DPP as a tool to build the data foundation of a science-based circular economy policy To assess progress towards circular economy targets, it is important to set in place a monitoring framework, built on reliable data. In this section, we describe how the Digital Product Passport could support such a monitoring framework. Currently, the European Commission uses the EU Circular Economy Monitoring Framework (CEMF) 32 . The framework is composed of a set of 11 indicators that capture the main elements of the circular economy. It provides information on 5 thematic areas: • Production and consumption (including material consumption, waste generation and green public procurement) • Waste management (focusing on recycling) • Secondary raw materials (and their contribution to raw material demand) • Competitiveness and innovation (in the recycling, repair and reuse sectors) • Global sustainability and resilience (minimisation of EU material needs and EU selfsufficiency) The current monitoring framework needs to be re-structured around clear goals, targets that define success, and indicators to measure progress. 33 Currently, some indicators are linked to existing targets (e.g. recycling rate targets), but an overall vision is missing. Objectives of the Circular Economy Action Plan (CEAP) are not included, such as enhancing circularity in a toxic-free environment or supporting the sustainable and circular bio-based sector. The monitoring framework has been designed to include only a few key indicators, focusing on providing a higher-level picture, but it lacks coverage of the 30 Ibid. 31 European Environment Agency. Briefing: Capturing the climate change mitigation benefits of circular economy and waste sector policies and measures. [Internet]. 2024. Available from: https://www.eea.europa.eu/publications/capturing-the-climate-change-mitigation 32 Eurostat. Circular Economy Monitoring framework. [Internet]. Available from: https://ec.europa.eu/eurostat/web/circular-economy/monitoring-framework 33 ECOS. Monitoring the EU transition to the Circular Economy. [Internet]. 2022. Available from: https://ecostandard.org/wp-content/uploads/2022/08/ECOS-Response.-Call-for-evidence-EUCE-Monitoring-Framework.-May-2022.pdf 17 four pillars. To ensure the monitoring framework supports action, it needs to reflect concrete objectives which collectively address all the pillars of the circular economy, and then the best indicators to measure progress against those objectives must be selected. The circular economy monitoring framework needs to rely on the best possible data while reducing reliance on assumptions and secondary data. The DPP has the potential to improve Eurostat datasets by providing detailed, product specific materials information that can be updated on an on-going quarterly basis. Currently, key datasets used in the framework, such as material flow accounts, are compiled by national statistical institutes using information from various sectors, often only annually, and with significant delays of several years. These datasets are used to model indicators like the material footprint indicator, which estimates the amount of virgin materials used in the economy. Consider that the DPP can be used to collect primary data on the material footprint of products for all products placed on the market, it could play a crucial role in delivering highly accurate precise and up-to-date material flow datasets. Importantly, the automated exchange requirements of DPPs can also allow this to be delivered on a low cost and upto-date basis, through direct DPP IT integrations with a bottom-up EU wide material flow accounts system. This will allow over time shifting from existing extrapolations-based input-output material flow accounting to direct calculations of materials placed in products on the EU market. And until DPPs cover 100% of a product group DPPs materials data can be used as complementary source to improve modelling. It will also allow for more fine-grained material flow modelling relating to specific product types and products such as washing machines or liquid plastic containers, or footwear. Exploring these possibilities could therefore significantly enhance the accuracy of material footprint calculations and, ultimately, and the effectiveness of circular economy policies by enabling better interventions at sector and product level. The monitored data needs to be designed so that it can be utilised to provide for policy interventions. The collection of materials and product data can be done with DPPs at a much more fine-grained level, per product types such as bedding mattresses, tyres, washing machines and other products. Thereby the circular economy performance can start to be measured per product type, with specific indicators and targets relating to the narrow, slow, cycle and regenerate pillars. The overall monitoring across the EU economy can be linked to Ecodesign interventions under the ESPR and other legislations per product group or even product type. To this end DPP can also be a source of additional data beyond materials that are not yet covered by Eurostat. As reported in the Global Circularity Protocol Landscape analysis 34 , the current circularity reporting metrics available lack data related to value retention and avoided impacts. For example, DPPS can also be used to monitor re-use if economic operators collecting products or managing reuse would do this systematically, which when combined with materials data can establish materials longevity indicators, and at a policy level to re-use performance requirements with associated interventions. To ensure that the DPP can feed into statistical accounts and improve decision-making, it must rely on strong data collection. Companies must be provided with clear methods 34 World Business Council for Sustainable Development. Global Circularity Protocol for Business Landscape Analysis [Internet]. 2024. Available from: https://www.wbcsd.org/resources/gcplandscape-analysis/ 18 on how to collect high quality primary materials data in a standardised way that is common across all DPPs and products. Especially, definitions and measurement methods of materials information and associated environmental parameters need to be crystal clear to ensure comparability across businesses. A critical instrument for this is the new ISO/IEC 82474 standard published in 2025 on material declarations 35 , which utilises standardised material lists for providing machine exchangeable materials and chemicals substance declarations. This horizontal standard is for any type of products and can form the basis for materials declarations as part of DPP materials information. As far as possible, core metrics which will be shared across product groups should be sector agnostic. They can then be completed with industry-specific metrics and industry-specific guidance on how to follow the core metrics. 36 In the initial phase, it is likely that the DPP will need to allow for some flexibility in the provision of primary data. Currently, companies do not always have access to primary data, either because they do not collect it from their supply chain, or because their providers withhold it for multiple reasons. It is therefore possible that companies may initially rely on secondary data to comply with legislation. The Commission should therefore define when and what secondary data are acceptable to use for providing materials information (e.g. reference datasets for a product type), but also design rules to incentivise the collection and sharing of primary data. Where appropriate, using secondary data should be less advantageous. For example, if a company uses industry averages to fill a DPP data obligation, the default assumptions should be conservative enough to incentivize the transition to primary data. Finally, when aggregating DPP data to feed into statistical accounts, there should be transparency on the proportion of primary data in the dataset. Ideally the dataset should only be used when a certain level of primary data is reached, ensuring the added value of the DPP dataset over current statistics. The appropriate level of primary data should be defined on a case-by-case basis, depending on the availability of alternative sources: if Eurostat data are of strong quality, that level should be high. However, if data is not currently available or very fragmented, the level may be lower if useful insights can still be inferred. Box 1 - Circular targets – the company level Besides European targets, the DPP could also support companies in setting their own circularity targets. By mandating that companies collect data upstream to calculate their material footprint, they would ensure that companies are aware of the environmental impact of their inflows. Currently, most company-level monitoring frameworks limit reporting to flows within organisations. This means that waste from upstream production is not accounted for. The Global Circularity Protocol Landscape analysis highlights the need to set the right data framework to guide not only policy making, but also business decision making.37 If designed with both objectives in mind, the DPP can reach its full potential in making environmental data available and becoming an enabler for the circular economy. Finally, enforcement is essential. Market surveillance authorities are expected to set up tools to easily verify whether a DPP exists for each new product being put on the market, 35 International Electrotechnical Commission. IEC 82474-1 Material Declaration. 2025. Available from: https://www.iso.org/standard/85487.html 36 Ibid. 37 World Business Council for Sustainable Development. Op. cit. 19 and whether it contains all the mandatory information. However, the verification of the data itself is likely to require more resources. It is not known yet which verification mechanisms will be favoured, between certification by external providers, verification by market authorities (most likely only when they suspect a lack of conformity) and selfdeclaration (i.e. no external verification). In all cases the automated exchange requirements of DPPs under the ESPR should be utilised for automated verification of datapoints in DPPs, to lower the cost of verification. Considering the current lack of primary data being made available, the European Commission should ensure that DPPs are closely monitored and controlled, while also providing guidance and recommendations to companies on improving data quality. Once the transition period ends, the sanctions foreseen in the Ecodesign for Sustainable Products Regulation (ESPR) should be effectively enforced to deter companies from providing misleading data. There is a significant risk that DPP data become marred with unreliable information. Unreliable information would not only prevent the DPP from achieving its objective, but it would also worsen the current situation by providing the illusion of knowledge, contaminating reports and statistics with inaccurate data. Box 2Example: the case of the food industry There is a precedent for product traceability: the agrifood sector. In response to several food safety scandal, the EU adopted the General Food Law in 200238, which created an obligation for all operators in the value chain to keep records on all the steps in the production, processing, transport and sale of food and feed products. Businesses need to know where their ingredients came from, and where their product went, following a “one-step-back” and “one-step-forward” approach39. The establishment of this system enables the sector and authorities to act fast when a problem is detected (a virus outbreak among cattle, a product fraud, a batch of food products unfit for consumption). It also provides data on the state of the food sector, informing public policies on issues such as the use of phytosanitary products, animal welfare, plant genetic diversity, etc. It demonstrates that businesses are capable of recording and sharing primary information about their products and production processes. 1.6 Recommendations 38 European Commission. Regulation (EC) No 178/2002 of the European Parliament and of the Council of 28 January 2002 Laying Down the General Principles and Requirements of Food Law, Establishing the European Food Safety Authority and Laying Down Procedures in Matters of Food Safe. 2002. Available from: http://eur-lex.europa.eu/legal-content/EN/ TXT/?uri=celex:32002R0178 39 M. Borit. 12 - Legal Requirements for Food Traceability in the European Union. Editor(s): Montserrat Espiñeira, Francisco J. Santaclara. In Woodhead Publishing Series in Food Science, Technology and Nutrition. Advances in Food Traceability Techniques and Technologies. Woodhead Publishing. 2016. Pages 225-235. ISBN 9780081003107. https://doi.org/10.1016/B978-0-08-100310-7.00012-0 20 • The European Union should ensure that circular economy policies across legislative files and standards coherently address all four pillars of circularity to avoid fragmented and ineffective strategies. • The European Union must integrate concrete climate change objectives in circular economy policies, to ensure that CE policies can effectively contribute to mitigating climate change. • The European Union must set binding, overarching material footprint reduction targets that are based on sustainable levels of resource extraction and consumption, as well as GHG emission reduction targets that are aligned with a 1.5-degree warming scenario. The upcoming Circular Economy Act should be used as the legislative vehicle for these targets. • The European Union must ensure that all circular economy policies define actions and that actions coherently address all four pillars of the circular economy. Actions should be aligned with quantitative targets and present a balanced mix of policy tools. The Circular Economy monitoring framework should integrate all pillars of the circular economy. Each objective must be linked to relevant indicators to assess progress against the objectives. • The Circular Economy monitoring framework have a sectoral declination, focusing on specifying progress at minimum at product group level (e.g. Energy related Products, textiles) and where possible also per product type (e.g. washing machines, garments), based on aggregating data from DPPs of products placed on the market per product type. • The European Commission and Eurostat should explore how data generated that can be contained in DPPs and exchanges on an automated basis to other IT systems, can be used to complement existing datasets or provide entirely novel direct primary materials data. • The European Union should define clear methods for companies on how to collect high quality primary data and incentivize their use over secondary data. • The European Union should ensure that the DPPs are closely monitored and controlled, and that recommendations are provided to companies to improve the quality of their data, and sanctions effectively applied. Note to readers: This policy brief is based in part on the findings of ECOS publication: Circling Forward to Sustainability: Unlocking the full potential of circularity to drive the green transition. Available from: https://ecostandard.org/publications/circling-forward-tosustainability/ 21 POLICY BRIEF #2: ENSURING CHEMICAL TRACEABILITY WITH THE DIGITAL PRODUCT PASSPORT 2.1. Introduction The widespread use of chemicals is a key characteristic to modern economies, with the European Union’s (EU) chemical production reaching 271 million tonnes in 2020 and consumption exceeding 289 million tonnes. 40 While over 26,600 chemicals are registered under the EU’s regulation on the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) 41 , this figure underestimates the true diversity of chemicals in products, particularly those in imported goods or used in small quantities. Despite their importance in manufacturing, many hazardous substances (endocrine disruptors, persistent organic pollutants, and carcinogens) continue to be used in consumer products, posing risks to both human health and ecosystems. 42 , 43 Chemical pollution has severe environmental and health consequences. Hazardous substances contribute to biodiversity loss, disrupt ecosystems, and persist in the environment for decades. Microplastic pollution, linked to synthetic chemicals in plastics, has reached alarming levels, with evidence of human ingestion through food and water. Exposure to toxic chemicals has also been associated with cancer, reproductive disorders, and neurological impairments. 44 Despite regulations like REACH, there is still a major data gap regarding which chemicals are present in products, at what levels, and their potential risks. 45 This lack of transparency is especially concerning for recycled materials, where harmful substances from electronic waste and plastics can re-enter products sold on the market. Recent studies have revealed dangerously high levels of toxic chemicals in toys made from recycled plastics, with dioxinlike compounds exceeding safe exposure limits for children. 46 To address these challenges, improving chemical traceability is essential for a clean, circular economy. The Ecodesign for Sustainable Products Regulation (ESPR) introduces the Digital Product Passport (DPP), requiring companies to disclose detailed information 40 European Environment Agency (2023) Managing the systemic use of chemicals in Europe. Briefing. Accessed on 4.3.2025 at: https://www.eea.europa.eu/publications/managing-thesystemic-use-of/managing-the-systemic-use-of 41 ibid 42 ibid 43 European Environment Agency (2024) EU Agencies: more work needed to make chemicals safe and sustainable. Press release. Accessed on 4.3.2025 at: https://www.eea.europa.eu/en/newsroom/news/make-chemicals-safe-andsustainable?activeAccordion=658fa19f-4f14-4f14-9a46-64f2f0a7b1e7 44 European Environment Agency (2023) op. cit. 45 European Commission (2020) Chemicals Strategy for sustainability. COM(2020) 667 final. https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A52020DC0667 46 P. Behnisch, J. Petrlik, C. Budin, H. Besselink, E. Felzel, J. Strakova, L. Bell, G. Kuepouo, S. Gharbi, F. Bejarano, G. K. Jensen, J. DiGangi, Y. Ismawati, O. Speranskaya, M. Da, J. Pulkrabova, T. Gramblicka, K. Brabcova, A. Brouwer (2023) Global survey of dioxinand thyroid hormone-like activities in consumer products and toys, Environment International, Volume 178, https://doi.org/10.1016/j.envint.2023.108079. 22 on product composition and sustainability. By embedding chemical traceability into the DPP, regulators, manufacturers, and consumers will be able to access product specific chemicals data, ensuring safer and more sustainable production practices. In particular, it can improve product design, providing incentives to phase out non-essential chemicals that may be of concern, and avoiding regrettable substitutions with just as problematic chemicals. Keeping material flows non-toxic from the start makes managing products’ end-of-life easier and prevents creating legacy chemicals that remain stuck in our products long after they were banned. This policy paper will address how the DPP can improve the traceability of chemicals in products, and what are the necessary conditions for the DPP to deliver on this objective. We provide policy recommendations based on the analysis. The paper covers: 1. State of play of chemical traceability 2. ESPR: a new dawn for chemical traceability? 3. The DPP: solving database issues 4. How to ensure that the DPP increases traceability 2.2. State of play of chemical traceability 2.2.1. Defining chemical traceability The DPP should enable chemical traceability that serves the policy objectives set out in the European Green Deal. As highlighted in the ESPR, the European Green Deal “aims to transform the Union into a fair and prosperous society, with a modern, competitive, climate-neutral and circular economy and toxic-free environment” . Regulating what goes into products and how much we know about it is central, as production processes and consumption patterns are the key drivers of current levels of material extraction, pollution and greenhouse gases emissions. In this context, chemical traceability should enable: • Phasing out hazardous substances to protect the health of consumers, workers, and the environment • Avoiding legacy substances of concern in production cycles • Encouraging the development and take-up of safe and sustainable chemicals • Improving efficiency in using chemicals, minimising use where possible To achieve these goals, chemical traceability should enable the identification of chemicals present in products 47 . Currently, there is an information asymmetry between companies that introduce chemicals in their products, and those who will buy these products for 47 J. Schenten, R. Niebler, M. Führ (2023) Traceability of chemcals in products for a non-toxic, resource-preserving and climate neutral circular economy. Workshop report. LIFE AskReach project. https://www.askreach.eu/wp-content/uploads/2023/01/AskREACH_TraceabilityWS_report_2023-01.pdf 23 further manufacturing, final use, or remanufacturing and recycling, as manufacturing specific product information is normally not provided when the product leaves the factory of the original producer. This information asymmetry prevents economic actors from making informed decisions. More specifically, producers should be able to know what chemicals are present in the parts they buy, to minimise the exposure of workers and to design safer and more sustainable products. End-of-life companies and especially recyclers should also have access to this information, notably on the presence of substances of concern, to protect workers, and ensure high quality recycling of secondary materials. Policymakers, public authorities, civil society organisations and researchers should know what chemicals are present in products, to improve the monitoring of chemical use, make recommendations and regulate the market appropriately to guide it towards the objectives mentioned above. Finally, consumers should be able to know what hazardous substances are in the products they buy so that they can avoid them, creating a information level playing field for consumers. They should also be able to choose the most sustainable products on the market, and for this, information on the presence of safer and more sustainable chemical alternatives is necessary. 2.2.2. Current EU traceability tools fail to trace back chemicals present in products Currently, several tools co-exist to provide information on chemicals in products. The below review shows that individually, none of the tools provide the necessary information described in the previous section. Collectively, they still only collect a partial picture. There is little to no interoperability between them 48 , rendering their use complicated for most data users. The Regulation on the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH)((EC) No 1907/2006) makes it mandatory for manufacturers to provide Safety Data Sheets for substances and mixtures that are classified as hazardous (according to the Classification, Labelling and Packaging (CLP) Regulation), are persistent, bioaccumulative and toxic (PBT), very persistent and very bioaccumulative (vPvB), or are included in the Candidate List of substances of very high concern (SVHCs) due to other properties. Safety Data Sheets include information on the properties and hazards of these substances and mixtures. They contain instructions for safe handling, disposal, and transport, and protection measures in case of exposure and in first aid situations. 49 These are primarily intended for workers in direct contact with the substances and provide safety and hazard information. The Safety Data Sheets are introduced at the level of the substance, not the products, cover only the most dangerous chemicals, and they do not intend to provide information to consumers. The Classification, Labelling and Packaging Regulation (CLP) ((EC) No 1272/2008) requires manufacturers, importers or downstream users of substances or mixtures to 48 O. Freudenthal, M. Da Silveira, L. Deladiennee (2024) Unlocking the potential of data harmonization and FAIRness in chemical risk assessment: lessons from practice and insights for policy development. Environ Sci Eur 36, 194. https://doi.org/10.1186/s12302-024-01022-4 49 J. Schenten, R. Niebler, M. Führ (2023) op.cit. 24 classify, label and package their hazardous chemicals appropriately before placing them on the market. Hazard labelling allows the hazard classification, with labels and Safety Data Sheets, to be communicated to other actors in the supply chain, including consumers to alert them about the presence of a hazard and the need to manage the associated risks. 50 The Classification and Labelling Inventory, maintained by the European Chemicals Agency (ECHA), is a database containing classification and labelling information on notified and registered substances received from manufacturers and importers. 51 However, this information is not useful when analysing the chemical composition of a product, as manufacturers of end products do not have to provide the CLP information for each substance present in the product itself. As there is no obligation to disclose the full chemical composition of products in most cases, the information is therefore lost at some point in the value chain. The EPREL (European Product Registry for Energy Labelling) database makes information about the energy and environmental performance of certain products available to consumers (households, bulk purchasers, public procurers). The information is based on data collected on products covered by the Energy Labelling Framework Regulation. However, the information included does not cover chemical presence, and the scope of product remains limited. 52 The SCIP (Substances of Concern In articles as such or in complex objects (Products)) database is currently the most developed tool for tracing chemicals in products. It was established under the Waste Framework Directive 53 and launched in 2020 to enhance transparency regarding hazardous substances in products. The SCIP database aims to encourage companies to comply with their duty to communicate the presence of any Substance of High Concern (SVHCs) in articles, make information accessible to waste operators to improve waste treatment, and help consumers make informed choices. Additionally, it serves as a comprehensive database for authorities monitoring SVHC use and supports enforcement activities. However, feedback from various users indicates that the SCIP database is tailored for companies submitting notifications more than for other stakeholders. According to data released in 2022, the database largely fails to offer useful and usable information as intended. An evaluation by ECHA acknowledges that SCIP is a promising tool but requires improvements to facilitate user experience and deliver true transparency. In particular, it is difficult for waste handlers, academia and nongovernment organisations (NGOs) to identify which articles contain notified SVHCs due to complex product categories, and consumers cannot easily find products of interest. 54 50 European Chemicals Agency. Understanding CLP. Accessed on 4.3.2025 at: https://echa.europa.eu/regulations/clp/understanding-clp 51 European Chemicals Agency. C&L inventory. Accessed on 4.3.2025 at: https://echa.europa.eu/regulations/clp/cl-inventory 52 EPREL website, accessed on 4.3.2025 at: https://energy-efficientproducts.ec.europa.eu/eprel_en#the-public-eprel-website 53 European Union (2018) Waste Framework Directive. (EU)2018/851. https://eurlex.europa.eu/eli/dir/2018/851/oj 54 Sofia, European Environmental Bureau, ClientEarth (2023) SCIP Database: Does it enhance transparency on Substances of Concern in a Circular Economy? https://rethinkplasticalliance.eu/wp-content/uploads/2023/10/SCIP-report.pdf 25 Finally, we can also mention additional databases such as the Cosmetic ingredient database (CosIng) and the Information Platform for Chemical Monitoring (IPCHEM). The first one is limited to the scope of the European Cosmetic Regulation. The second one gathers information from different types of chemical monitoring, included some data on products. It is intended for policymakers and scientists to identify levels of chemical pollution in society, rather than the presence of specific substances in specific products. 55 To conclude, chemical traceability should allow tracing of chemicals present in products, to avoid the recycling of waste and integration of their legacy substances of concern into new products, and to encourage the efficient use of safer chemicals. However, the lack of information on which chemicals are used in different processes, materials and products is still a major barrier to environmental and human safety as well as to the efficient regulation of harmful substances. Current data sharing tools cannot help actors along the product lifecycle to make the right decision and phase out harmful chemicals, find adequate substitution, minimise chemical use, and handle products safely. 2.3. ESPR: a new dawn for chemical traceability? 2.3.1. Introduction to the ESPR The ESPR is a general framework for upcoming product-specific legislation adopted in 2024. It replaces the Ecodesign Directive 2009/125/EC and broadens the scope of products to nearly every product on the European market. While work on steel and textiles has started, other priority products will likely include furniture, tyres, and aluminium. The legislation identified several other product sectors, including detergents, paints, and lubricants, while the EU’s Joint Research Centre (JRC) analysed some more sectors in its preliminary study 56 , such as absorbent hygiene products, toys, and cosmetics. Additionally, plastics and polymers were included in the JRC study, but this sector has not yet been formally identified as a product category. The ESPR will extend sustainability requirements beyond the current directive’s energy efficiency requirements to include durability, reusability, reparability, presence and use of substances of concern, recycled content and recyclability, and environmental footprints. The framework has also included information requirements on these aspects which will be communicated via Digital Product Passports. 2.3.2. Chemicals in ESPR Regarding chemicals, the ESPR is the first legislation to broadly address chemicals in products. The ESPR focuses on substances of concern, which are broadly defined to include many substances that may have a negative impact on human health and the 55 O. Freudenthal, M. Da Silveira, L. Deladiennee (2024) op. cit. 56 Faraca, G., Ranea Palma, A., Spiliotopoulos, C., Rodriguez Manotas, J., Sanye Mengual, E., Amadei, A.M., Maury, T., Pasqualino, R., Wierzgala, P., Perez Camacho, M.N., Alfieri, F., Bernad Beltran, D., Lag Brotons, A., Delre, A., Perez Arribas, Z., Arcipowska, A., La Placa, M.G., Ardente, F., Mathieux, F. And Wolf, O. (2024) Ecodesign for Sustainable Products Regulation: Study on new product priorities, Publications Office of the European Union, Luxembourg, https://publications.jrc.ec.europa.eu/repository/handle/JRC138903 32 • The EU Commission must ensure that the DPP is integrated with other chemical databases to facilitate information reporting and sharing. The automated data exchange setups of DPPs need to be utilised in making these linkages, so as to enable low-cost and useful chemicals information management. • Policymakers must align the definition of confidential business information with the EU Regulation on Persistent Organic Pollutants to protect human and environmental health • Policymakers must add new due diligence requirements to document and record important characteristics of WEEE containing CRMs. Then, policymakers and public authorities must ensure that the information is indeed used. The use of DPP chemical data must encourage the phase-out of hazardous substances and their replacement with safe and sustainable chemicals. To achieve this: • The DPP must be designed to facilitate access to safety information for workers and ensure that problematic legacy chemicals are phased-out from circular value chains. To achieve this, industrial actors must implement tools and infrastructures to incorporate the use of DPP information in their processes. Workers should be trained and empowered to identify and safely discard materials that contain substances of concern when collecting used parts or secondary materials. • The DPP must enable consumers to identify products with safe and sustainable chemicals, and chemicals with substances of concern to facilitate consumer choice. The DPP must also facilitate consumers’ access to safety information. • The DPP must have differentiated access for public data and additional safety data for all chemicals, going beyond substances of concern, especially for agencies and experts carrying out environmental and human safety studies and screening of chemicals in products. Here also automated data exchange is of significance on a secure basis, to enable speed and lower the cost of chemicals assessments. • Policymakers and Public authorities must use the DPP to monitor the use of chemicals in products to improve the regulation of chemicals. This information should also be available to researchers and civil society. • Market authorities must use the DPP to reduce the entry of non-conforming and dangerous products on the EU market. Any missing data should be considered as a lack of conformity. Finally, while chemical traceability is a key foundation to effective chemical regulation, it cannot replace the mandatory restriction and substitutions of substances of concern. The planned revision of REACH should ensure that hazardous substances do not enter the value chain. Product regulations should also ensure that products are safe for both consumers and the environment, and that their production and processing does not put workers and the environment at risk. 33 POLICY BRIEF #3: PRODUCT LIFECYCLE INFORMATION FOR CONSUMERS 3.1. Contents Overview The purpose of this paper is to explore the role and functionality of a Digital Product Passport (DPP) once a product is in the most active part of its lifecycle – the use-phase. Once a product has been made, packaged, marketed and sold to a consumer, communication or relationship with the manufacturer typically ends. How the product functions, its level of performance, care and maintenance is largely unknown to manufacturers. The need or motivation to reconnect is typically when the consumer has an issue with the product, such as a fault, or because it is no longer wanted or needed. At this stage, the need to find information about repair or disposal is urgent and information is not always so easy to locate unless the consumer is determined or environmentally conscious. Whereby, the likelihood of a product being repaired, remanufactured or properly recycled is down to the information available to the consumer and their motivation/ability to access it. This paper identifies policy recommendations to address the void of communication that happens during the use-phase of a product. It further supports gaining an understanding of how learning more about this crucial period of time can help ensure products remain in use for longer and which insights can be gathered that allow for eco-design objectives (as detailed our eco-design Policy Paper 70 ) to be realised based on consumer insights. The main challenge is that consumers do not have a need or desire to share information about their product use or daily habits (such as their frequency of using a washing machine, which setting they typically use and the type of laundry liquid they have) with manufacturers. There is a missed opportunity to create an ongoing relationship between manufacturer and consumer. This paper seeks to draw insights gathered from consumer surveys and discussions with consumer organisations as to how this opportunity can be exploited and how legislation can ensure that the consumers’ point-of-view and needs are included in the design and functionality of a DPP. 3.2. Information flow from viewpoint of consumer One of the key objectives of a Digital Product Passport (DPP) is to be a central point to access data about a product at any point in its lifecycle by whoever needs that data to reduce its environmental impact and keep it in use for as long as possible. When considering the type of data that a consumer might need to access about a product, it was identified as often being data which a consumer needs to “take” from a company (such as the manufacturer), such as product specification or how to get it repaired if it breaks. 70 https://circthread.com/download/policy-brief-2-eco-design-in-the-context-of-the-dpp/ 34 The current challenge that a DPP could help address is for manufacturing companies to gain insights and feedback on how the product is used or performs after purchase. This would require the consumer to “give” data back – which happens much more rarely. The different types of data flows are mapped below: Type of data demand Stage of lifecycle Data needed/provided Location of data need Urgency of data need Currently available TAKE from companies Purchase Product specifications and performance such as manufacturing date, serial number, energy efficiency label, and product durability. Online or in physical store Medium/High Yes TAKE from companies In use Warranty, mandatory inspections, maintenance history, error alerts with possible solutions, reminders for inspections, preventive maintenance options. Online High Yes, but time consuming. TAKE from companies In use Information regarding replacement parts (e.g. cartridges in printers, bags in vacuum cleaners, replacement batteries, etc.) Online High Yes, but time consuming. Not always provided by the manufacturer but by 3rd party companies, repairers or independent organisations TAKE from companies Repair Details and location of engineer, cost and speed of repair, status of the repair, spare parts stores, guide for small home repairs, how to access specific repair maps/guides for the product (for 3rd party repairers) Online High Yes, but time consuming TAKE from companies Second life Second hand and or refurbished shops to sell it if still functioning. Online High Yes, but time consuming TAKE from companies End of life Location of recycler, cost of collection or opening times to deliver Online Medium Yes, but time consuming GIVE to companies Use Frequency of use, settings chosen, servicing or preventative maintenance undertaken Online None No GIVE to companies Repair Details of repair (cost and issue) Reasons repair was not done (such as cost or time) Online None No 35 GIVE to companies End of life End destination of product – donated, sent for recycling etc. Reasons for sending to recycling e.g. repair was not possible, value not worth repair, change of tastes Online None No Data “take” from companies Product information is readily available and provided by manufacturers. Recycling and repair information is available to a lesser extent, or it is harder to find, often provided not by the manufacturer but independent organisations, local authorities or consumer groups and so is also being country/region specific. But data is available and consumers have a reason/drive to access this data in order to make an informed decision – be it which product to choose or whether to repair or replace. Data “give” to companies Gaining insights on how a product is being used is challenging to collect from consumers. How they use a product will be useful to know how it can be better designed for energy/water efficiency or to replace parts that are frequently breaking. Knowing why they did not repair would be helpful, as well as what caused the break. But there is no drive or incentive for consumers to share this information with manufacturers. Consumers are busy and do not necessarily think about their interactions with products until they malfunction. Privacy is a major concern around giving of data. Users might be uncomfortable with the idea of providing personal information like address, phone number, or ID number. During the Spanish pilot, some users expressed concerns about the privacy of their data, questioning who will have access to their personal information. They noted that it is possible to trace the product owner through invoices, the use of smart appliances, or if the consumer logs in with their email or personal data. This raises concerns about how their information will be handled and protected. 3.3. Consumer drivers for accessing or sharing data A survey was conducted under WP3.2 (Consumer information, experiences and expectations regarding circularity of Small & Large Household appliances, High Tech devices and Heating systems) to gain a better understanding of the consumer’s data demands. The survey identified that 85% of European respondents were willing to register their purchased products on a platform, as long as their personal data was not included. According to that survey, the type of information consumers are most willing to share includes reporting issues, describing breakdowns and malfunctions, notifying when an appliance has reached the end of its life and is ready for recycling, and providing details about repairs and replaced parts. On the other hand, the least shared data would be usage information or photos of their products. 36 By asking questions about consumer experiences when buying a product and willingness to share use-phase data, the following key conclusions can be drawn from the survey results: • Economic feasibility is an overlaying determining factor for consumers when making decisions. • The low level of post-purchase information highlights a vacuum of communication between consumers and manufacturers. • There is a very low drive for consumers to share data which highlights the difficulty manufacturers or designers currently have in gathering consumers’ insights to meet eco-design requirements. • There needs to be a benefit to consumers to make them act differently. According to the European Commission, the premature disposal of consumer goods produces 261 million tons of CO2-equivalent emissions, consumes 30 million tonnes of resources, and generates 35 million tonnes of waste in the EU each year. Consumers also lose about €12 billion yearly by replacing goods rather than repairing them. The survey also provided insights into how to address this environmental and economic loss: 3.3.1. Key consumer trends regarding repair • On minor breakdowns, 40% of those surveyed tried to mend the fault themselves, showing that there is a demand for information that facilitates this. However, repair guidance needs to be available for free as paying even a small fee for such data is not seen as worthwhile unless the breakdown is recent. • Reasons typically given for not repairing a product are varied but typically were cited as repair being too expensive, the product too old, a preference for a new product and even deciding to live with the problem (if fault is minor). • Data needed by consumers include approximate cost of a repair, maintenance guidelines and guarantee or warranty information. The common overlaying factor to consumer decisions is economic feasibility. The decision to repair or not is very subjective at present in the absence of good systematic information on issues and faults that is easily accessible for consumers. This is needed to guide consumer decisions to explore this route, especially if it can save them money (such as a YouTube tutorial to self-diagnose a minor problem). DPPs could in the future include repair data such as a score from a Repairability Index (as currently used in France). The challenge here is that the repair score is not a hands-on decision support, on how to repair a product, or who to engage for repairing a product, and providing a better more open repair market. This could be addressed with video tutorials provided by manufacturers on how to perform minor repairs and access the appropriate spare parts. For repairs that require specific competences or tools and that should only be made by a professional repairer, information from manufacturers should be made readily available to independent repairers, increasing availability and proximity of repair options to consumers. For the repairers themselves, there is then an opportunity to raise their own profile with consumers, using their repair experience to stimulate competition with other repairers, increase demand for spare parts and work to dispel the stigma around repair and 37 reuse. Indeed, in Austria 71 , there is a repair bonus scheme that allows consumers to claim back 50% of the repair cost (up to €200) by booking a repair of bicycles and electronic items with one of 1200+ companies that have joined the scheme. A repair is booked online, generating a voucher that is then redeemed. The scheme is paid for by The Federal Ministry for Climate Protection. Another concern is that a Repairability score is currently based solely on data from the manufacturer, using criteria for ease of disassembly, available documentation to repairer or a consumer, the price and availability of spare parts and product specific aspects such as software. Whilst highly useful, to create improvements in repairability, the use of DPP verified consumer-data on repairability would be very valuable to enhance the data provided by the manufacturer and/or other 3rd parties. There is no direct link for this in the French repair score, which fails to indicate product durability and so does not reflect the reality of user experience - namely where the consumer has issues and needs guidance on repair decision making. Using data based on consumer feedback and user experiences, would allow the real repairability of a product to be gauged. The repairability of a product is also impacted by the intensity of usage, the value of product as to if something is not just possible to repair but whether the consumer considers it commercially feasible. Other considerations also come into play such as urgency of need to wait for a repair and the consumers’ view on how worthwhile replacing something a few years old versus buying new (due to concerns about repeat failures etc.). To reflect these nuances, in France the introduction of the Durability Index (see Annex for more details) which will come into force for washing machines and televisions (smart phones were meant to be included but will now be covered by the new European Energy label that will include a repairability index) and will be a scale from 1-10 with a coloured index. The higher the score the more durable the product. Published on 5th April 2024, it came into force in January 2025 for TV and April 2025 for washing machines. Given that DGCCRF, the French anti-fraud authority, inspected the Repairability Index ratings in 2022 of over 500 organisations and found 65% of them had questionable methodologies for calculating the end Index number 72 , more use-phase data is desperately needed to ensure their numbers are means tested. Data from consumers will be invaluable to qualify these index scores as the life of a product is still calculated using theoretical use or manufacturer data on expected component life-expectancy. 3.3.2. Key barriers for consumers to share use-phase data Having analysed the survey results, a number of subsequent questions were tabled in a CircThread workshop and meeting attended by manufacturers and consumer organisations in Porto in June 2024. The objective was to get a better understanding of how a DPP can best position itself to address the concerns raised by the survey. To identify 71 https://www.reparaturbonus.at/ 72 https://www.sgs.com/en-gb/news/2024/06/safeguards-8724-durability-index-for-washingmachines-and-televisions-in-france 38 the barriers or concerns that consumers have regarding “giving” data to a DPP and to table ideas for ways to incentivize consumers to share use-phase data. From these discussions, the following trends were identified: • A lack of trust about sharing data and need for assurance of privacy • Privacy concern related to the fact that any insights shared might generate unwanted sales emails or adverts if a manufacturer knows (for example) that a guarantee or warranty is going to end imminently. A number of incentives were discussed as detailed in the Annex. What is evident is that a co-ordinated approach is needed with manufacturers working hand-in-hand with consumer associations to ensure the messages that are shared by manufacturers on packaging and in-store communications is supported (and at times validated or even challenged) by the consumer organisations to give consumers confidence in engaging with a DPP for their product after the purchase phase. 3.4. A DPP can facilitate an ongoing communicative relationship with consumers Currently communication with and building of a relationship with consumers stops after product purchase which results in the creation of a data void until there is a problem such as a technical fault. A real opportunity for the DPP is to be a platform that can keep consumers connected with the manufacturer or a 3rd party organisation that services the product during the usage phase by developing a symbiotic relationship where information is shared for mutual benefit. For this to work, there needs to be qualitative benefits or ongoing reasons for a consumer to “give” their use-phase information. Some suggestions are given below: “TAKE” FROM COMPANIES Information a DPP can provide consumer “GIVE” TO COMPANIES Data consumer would share in order to gain access to DPP information Show the date that a guarantee or warranty expires and so confirm if a required repair would be free or incur a cost Upload date of purchase and reason for choice of that model including option to upload purchase invoice/receipt for safe keeping Postcode location of repairers including their phone number/website The ability to enter postcode by the products’ owner to search for repairers in a specific proximity radius How to do basic fixes and troubleshoot themselves to avoid calling a repair engineer Share details about the failure including what led to the issue or any noises, visual defects or error messages experienced Estimation of repair cost – to explore ballpark cost rather than call engineer and get a shock cost Share details about the failure including what led to the issue or any noises, visual defects or error messages experienced Valuation Assessment – suitability for donation or resale (similar to a car valuation website) How product is typically used such as frequency and settings, age of product, existing faults and cosmetic condition 39 Provide links to approved refurbished product websites when consumers search for disposal options for a product. This would raise awareness of an alternative to buying a new replacement product Able to view past history of a refurbished product and reasons for resale (e.g. cosmetic damage) to provide confidence in purchase Free online “health check” for optimal use of a product to keep it working for longer (clean filters, use of certain modes, optimal product location, water and energy efficient settings) How product is typically used such as frequency and settings Tailored advice on how to make economic savings How product is typically used such as frequency and settings and if used by a family of 4 or a solo person Recommendations for a suitable product based on different user profiles. This would support pre-purchase decision to ensure capacity or output of product matches consumer need. The number of adults/children in a household, size of typical laundry loads (2kg or 10kg) or required frequency of product use Generate a reward code or voucher to allow user to get quicker collection for recycling or offer discounted repair of product (as currently done in Austria) Can prove history of product use including age and level of care/maintenance, previous issues etc. Access to a community forum where advice and help can be shared, including from ‘expert engineers” Share details of the problem the consumer has including model and age of product, level of usage It should be noted that whilst the above list are proposed ideas of additional information that consumers would gain access to in return or as a reward for sharing their use-phase data, there is some data that manufacturers or 3rd party organisations must provide, regardless of what a consumer shares. This includes information on manufacturerapproved repairers, spare parts and user manuals. 3.5. A DPP can facilitate an ongoing communicative relationship with consumers When considering policy recommendations to support consumers’ sustainability journey, it is important to consider the inter-play of related existing legislation: The Consumer Rights Directive focusses on ensuring strong rights for consumers including information they should have access to and their right to cancel online purchases. It is amended with the addition of the EU Directive to Empower Consumers for Green Transition 73 whose objective is facilitating consumer access to information on durability, repairability and legal guarantee rights. Having entered into force in March 2024 but not into application until 27th September 2026, it also guards against unsubstantiated “green” or “eco-friendly” claims and the use of early obsolescence. Any claims made need to be verified by a third-party expert. 73 https://eur-lex.europa.eu/eli/dir/2024/825/oj 40 The intention is for this legislation to give consumers confidence in the validity of the claims being made so they can make informed choices at the buying stage. This includes: • Making consumers aware of features that will limit the durability of a product • Prohibit any features that might purposely stimulate the replacement of a product • Prohibit urging replacement of parts sooner than necessary (such as ink in a printer) • Communicating to the consumer if the use of parts or elements that are not provided by the original producer will limit a product’s functionality • Ensure consumers are well aware of availability of free upgrades • Make the existence and duration of any commercial guarantee of durability easily known by the consumer. Should not be required to actively seek such information from the producer, for example, by searching on product-specific websites • Use of obvious and eye-catching product labels to provide data on guarantees or durability • Prohibit any claims of a product lasting for a period time under “normal expected use” when is actual fact, this is not the case in reality This last requirement will greatly depend on the input of data from the consumer on their use of a product to determine what “normal use” is. A DPP could be used to offer evidence to support any claims of non-compliance under this legislation and act as the much-needed consumer facing information portal to show compliance for producers also. Without this, such legislation will have limited impact for consumers. The Green Claims Directive supports and operationalises this new legislation by ensuring producers cannot make false or ambiguous statements about the environmental benefits of a product without the support of verified data. Adopted in March 2023, this legislation extends to the use of labels and logos (which is vital for consumers who are bombarded by over 230 sustainability labels and 100 energy labels 74 ) as over half of them offer weak or non-existent verification. By making it essential for manufactures to provide clear criteria and proof of their environmental claims and labels which have been checked by an independent and accredited verifier, it should boost consumer confidence in using such data to make their buying choice. Whilst any claims made by manufacturers on repairability and durability is covered by this legislation, both of these pieces of policy focus primarily on the provision of information and knowledge at the purchase phase of the consumer experience. For the important post purchase phase of the consumer experience, the Right to Repair Directive 75 was adopted in June 2024 and must be implemented into national law by Member States by mid-2026. This legislation encourages repair and reuse of products both under guarantee but importantly, those out of it also. Obligating manufacturers to facilitate the repair of product in a reasonable time and cost, making spare parts readily available for longer and at a reasonable price. 74 https://environment.ec.europa.eu/topics/circular-economy/green-claims_en 75 https://commission.europa.eu/law/law-topic/consumer-protection-law/directive-repairgoods_en 41 Sharing data on websites also on approximate costs of typical repairs and the provisions of a searchable database of repairers will make the process of repair far less stressful or daunting for the consumer. It should be noted that such websites and databases must include and promote independent repairers to widen the availability and choice of repair options. This is essential to stimulate a repair market that is affordable and worthwhile for the consumer and so is a key recommendation listed in the next section. Repair will also be rewarded for the consumer under an amendment of the Sale of Goods Directive whereby consumers get an extra year of the legal guarantee if they choose to repair the product instead of replacing it under the legal guarantee. This Directive will greatly empower the consumer by demystifying the repair experience and making it a truly viable option. The DPP being the portal for the searchable database could incentivise consumers to share their data with the DPP also. 3.6. Recommendations for a DPP to facilitate the sharing of use-phase consumer data Drawing on insights gathered from the surveys, workshops and discussions with industry and consumer organisations, a number of policy recommendations have been outlined below. The objective is for the DPP to facilitate a symbiotic relationship between consumers and other stakeholders in the product lifecycle (manufacturers/repairers/recyclers) by making the gathering of and learning from usephase information both easy and secure: 1. Wider list of approved repairers – consumer organisations support the call for small independent repairers or community initiatives such as repair cafes to be listed as options, rather than solely engineers/technicians employed or subcontracted by the manufacturer, to ensure the widest range of repair options. For this to be achieved, there needs to be an independently defined set of repair standards that all repairers must provide proof of conforming to. This would also provide consumers’ confidence and reassurance that the use of “non-official” engineers will not negatively impact any warranties or guarantees. Policy recommendation - Support the obligations of the Right to Repair Directive by developing of an independently defined set of Repair Standards which repairers must comply to in order to be listed on DPP. Such data can be included on the EU repair platform that the Directive will have operational by 2027 where local authorities will be required to provide visibility on a map of the repairers in each country. This will further add to the objective of empowering consumers to make repair choices with ease and confidence. 2. Increased opportunities for consumer interaction – consumers receive or can find a lot of information when buying a product but the level and reasons to interact with consumers reduce significantly after purchase. There is no motivation on either side to connect until there is a need for help with a breakdown or finding how to recycle a product. This is a significant missed opportunity for manufacturers to learn how consumers are actually using their products in the home and any design frustrations or issues there might be. Having a reason to “check-in” and discuss issues with a consumer can be an opportunity for manufacturers to also improve the design of future products such as different washing cycle settings or to identify that a door clasp keeps jamming and so is likely 48 material composition, quantity, location, and quality, using algorithms to recommend reuse scenarios. According to EME, their platform has identified reuse solutions for over 100,000 tons of materials. Similar marketplaces and industrial symbiosis platforms are emerging across Europe (e.g. Italy’s Symbiosis platform) 92 which demonstrate circular economy loops where one firm’s waste becomes another’s input, enabled by transparent data sharing on material availability and specifications. Consumer guidance: Consumer-oriented information within a DPP can provide guidance for more sustainable choices such as repair options over disposal or informing consumers about nearby drop-off points or second-hand markets. Accessible and actionable sustainability data can help educate consumers and provide transparency on sustainability data, for instance, Sitra tested a pilot in Finland to circulate logistics emissions data for transported goods, aiming to show end users how the carbon footprint of a product accumulates. Furthermore, feedback input by consumers through DPPs (as discussed more thoroughly in Policy Brief #3 on Product Lifecycle Information for consumers), could provide valuable information for improving products’ sustainability (e.g. usage data for energy efficiency, identification of product issues for durability improvement etc.), as well as to have a more realistic view of how products are actually used after purchase, their reasons for needing repair and the data needs that consumers have to facilitate repair or recycling of products at end of life. Compliance and regulatory uses: Data spaces can help measure progress on circular economy targets providing policy makers and researchers to access harmonised data on material flows, recycling rates, and other datapoints to improve evidence-based decisionmaking for environmental policy. 93 Current repositories of circular economy indicators such as those provided for Eurostat 94 for instance, while useful for high-level comparisons of circularity across countries, lack detail to be able to assess complex policies at the national or sub-national level or to monitor related impacts. Further, digital tracking across environmental agencies can help ensure valuable materials are monitored to facilitate them re-entering production. Furthermore, synergies in reporting requirements for companies for multiple regulations can be optimised so that companies do not have to report the same information multiple times, thus reducing and simplifying their administrative burden for companies. Some countries are also developing national waste data spaces. For instance, the UK (although non-EU) is set to introduce a mandatory digital waste tracking service in 2025 to record all waste movements in a unified database 95 . In summary, circular application data spaces have the potential to improve the traceability and transparency of materials, as well as cultivating a collaborative environment where stakeholders across the supply chain can work together towards circularity objectives. 92 https://www.interregeurope.eu/good-practices/symbiosis-platform 93 https://www.circle-economy.com/blogs/data-drives-the-circular-economy-needs-andtrajectories-for-leveraging-data-for-good 94 https://ec.europa.eu/eurostat/web/circular-economy 95 https://www.gov.uk/government/publications/digital-waste-tracking-service/mandatorydigital-waste-tracking 49 Nonetheless, there are factors and challenges that must be addressed to ensure data spaces can fulfil their full potential. These are discussed in the following section. 4.4. Key requirements for implementation of Circular Applications Data Spaces The success of the DPP and its integration into the EU's data spaces will depend on robust governance, data protection, and the development of common standards to ensure interoperability across sectors. Data governance models must have clear rules and processes on factors such as access and control, data-sharing agreements and authentication, so that stakeholders can confidently share information without undue fear of data leaks or misuse. This trust is essential for fostering collaboration across traditionally siloed value chains. A key challenge is ensuring that data providers have control over their information while still allowing transparency for circular economy objectives. Industry stakeholders have expressed concerns on potential misuse of confidential data, such as proprietary methodologies. If not addressed, these concerns could limit the willingness of businesses and consumers to participate in data-sharing initiatives. A decentralised structure of data spaces can allow data providers to retain control over their own information, wherein rather than collecting everything into a single repository, each participant maintains local databases and exposes relevant data via secure ‘connectors.’ However, for this to succeed there must be clearly defined rules of engagement: Accessibility and usage: Differentiated access to data for each stakeholder in data spaces is key to protecting information, and this is already captured in the ESPR. As William Neale, adviser in DG Environment explained regarding DPPs: “when it comes to intellectual property, privacy, and so on, we need to make sure those are dealt with either through encryption or through making data available at a later date… We’re talking about a decentralized or distributed approach to the data. It does not have to move from where it’s created.” 96 As outlined in D4.5, the International Data Spaces (IDS) framework provides a structured approach to addressing these challenges by defining data contracts between the data provider (entity making the data available) and a data consumer (the entity requesting and using the data). The goal being to ensure that data sharing occurs under clear and enforceable terms agreed upon by both parties. A data contract outlines the specific conditions, permissions, and restrictions that govern how the data may be accessed and utilised. These contracts are machine-readable and automatically enforced by the IDS components. 96 https://www.circularise.com/blogs/digital-product-passports-dpp-what-how-and-why 50 Data contracts can include one or more usage policies which define how the data can be used, what is prohibited, and what obligations must be fulfilled (e.g., delete data after usage, or provide notifications). As outlined in D4.5., usage control policies can include: • attribute-based control (grants or denies permissions based on user credentials, dataset category, or contractual obligations); • time-restricted access (limits data usage to a predefined timeframe (e.g., two weeks, six months); • event-based restrictions (triggers automatic permissions based on specific conditions); • encryption enforcement (so that shared data remains encrypted, reducing the risk of unauthorized access); • deletion policies (mandates the automatic deletion of data after a set period or after a specific number of uses). Privacy and anonymisation: Data spaces must incorporate mechanisms to ensure anonymisation in line with individual privacy is preserved (including GDPR compliance) so only relevant information is shared. The role of data intermediaries: For data spaces to function smoothly, participants need clarity on who governs the data space, how disputes are resolved, and what legal liabilities exist. The DGA introduces the concept of data intermediaries (with certain legal obligations to neutrality and fair play 97 ) that connect individuals and companies with data users. Neutral data intermediaries or platforms can play a role of coordinate interactions, and indeed companies have expressed the need for support from data-sharing functionalities provided as a service. Data intermediaries can help manage growing data volumes and the increasing complexity of transactions across value chains. Within the decentralised structure of data spaces, it may be beneficial to have a multistakeholder governing board or data support centres that play a role of overseeing dispute resolution mechanisms and the implementation of access policies and adherence to standards. This could help maintain trust by providing collective oversight. For example, the Green Deal Data Space initiative formed an association to coordinate participants and ensure compliance with common rules, acting as a governance body.In the case of the IDS framework, a Clearing House records and stores all interactions between a Data Provider and Data Consumer, serving as a log for the contract. If a dispute arises (e.g., a provider accuses a consumer of misusing the data), auditors can review the exact contract terms that were agreed upon and verify whether the consumer’s usage aligned with those terms. Furthermore, the IDS framework allows for ‘automated negotiation’, as the process of negotiation for the contract is machine-interpretable so that the data space infrastructure can monitor whether the terms of the contract are being adhered to. A relevant example of intermediaries is Simpl 98 which is under rapid iterative development to forms an IT communication basis for single data spaces to existing IT services, and even will allow for linking of different data spaces. Simpl acts as an open-source middleware architecture that: i) establishes interoperability through standardised interfaces ii) 97 https://digital-strategy.ec.europa.eu/en/policies/data-intermediary-services 98 https://digital-strategy.ec.europa.eu/en/policies/simpl 51 implements data usage policies at multiple touchpoints to ensure data sovereignty and iii) has a federate design that integrates decentralised ownership of data. Data interoperability and standards: A fundamental challenge is ensuring that diverse data (from different companies, sectors or countries) can coalesce together. Information about products and materials can be in incompatible formats and systems, making it difficult to exchange. Different actors using variable data standards for parts or material specifications for instance, can make it difficult to aggregate information. Further circular data spaces may be inherently multi-sectoral, thereby needing to accommodate data from various domains under one space. It is necessary for robust standards and taxonomies for materials and products to enable seamless data sharing, as well as to ensure the quality of data. There are ongoing standardisation efforts aiming to address these needs. For instance, on 20 September 2024, CEN and CENELEC launched a new joint Technical Committee, JTC 25 ‘Data management, Data spaces, Cloud and Edge’, which will focus on developing standards for data interoperability, quality and organisational frameworks amongst other areas. Focusing on data quality, lifecycle management, and cloud-edge interoperability, JTC 25 aims to help align industrial practices with evolving EU data legislation (e.g., the Data Act), to be able to provide a more consistent, future-proof standardisation landscape for data spaces. Technical Committee Structure Scope Preliminary work items CEN/CLC/JTC 25 - Data management, Dataspaces, Cloud and Edge • CEN/CLC/JTC 25/WG 1 - Advisory group • CEN/CLC/JTC 25/WG 2 - Dataspaces • CEN/CLC/JTC 25/WG 3 - Data management and governance • CEN/CLC/JTC 25/WG 4 - Cloud & Edge Standardisation in the area of data management, dataspaces, cloud and edge, including: • data governance, data quality and data lifecycle management; • interoperability, portability and switch ability; • organizational frameworks and methodologies, including IT management systems; • processes and products evaluation schemes; • smart technology, objects, distributed computing devices, data services. • Implementation framework for trusted ontologies and data models • Trusted data transactions • Maturity assessment of Common European Data Spaces • Quality assessment of internal data governance processes • Implementation framework for data catalogue (DCAT) profiles and extensions. 52 Furthermore, the EU’s Rolling Plan for ICT Standardisation 99 puts forth activities to connect EU policies to standardisation efforts in more than 30 technological domains, including actions for developing an open architecture framework for DPPs and circular data. For instance, in relation to useful recycling data, standards that could provide a basis for creating guidance on material identification, classification, and reporting include: IPC175x family, Materials Declaration Data Exchange Standards, establishes a standard reporting format for data exchange between supply chain participants. Further standards are available through the CircThread standardization toolkit. Technical and financial barriers: Companies will need to invest in new IT technologies and setup new IT infrastructure, upgrade systems, and train staff. Upfront costs can present a barrier, in particular for SMEs. While current pilots of data spaces showcase circular benefits of data sharing, these can be difficult to quantify in the short term, and scaling their results across industries is a challenge. Lowering the technical complexities of both setting up data spaces and connecting to them for SMEs is critical. Financial incentives (e.g. public procurement, funding programs) especially for SMEs, will be crucial in early stages to help launch data spaces to evolve them to the point where the benefits outweigh the costs of IT investments. Furthermore, a cultural shift will often be needed for companies to embrace data transparency given traditionally siloed data. Fostering trust and datadriven cooperation will be a process that will take time. Monitoring: The complexity of global supply chains and data being spread across multiple systems and jurisdictions is a challenge for information exchange. Monitoring of crossjurisdiction, non-EU related data will be important and hinges partly on use of internationally interoperable standards. Furthermore, auditing of dataspace participants to ensure compliance with security and privacy standards is also needed so that participants can have confidence and trust in the system. 4.5. Conclusions and Recommendations for Circular Applications Data Space EU policies are crafting a legislative space to enable the implementation of Circular Application Data Spaces and their implementation and contribution to circular economy goals. The DPP and data spaces can address the information gaps that have limited circular economy initiatives—such as inadequate visibility into product composition, poor traceability of critical raw materials, and insufficient feedback loops between consumers, manufacturers, recyclers, and end-users. Circular Applications Data Spaces thus have the potential to facilitate collaboration, innovation and synergies across stakeholders throughout the supply chain for more sustainable economies. 99 https://interoperable-europe.ec.europa.eu/collection/rolling-plan-ict-standardisation/circulareconomy 53 However, achieving the envisioned objective of data spaces becoming tools for circularity requires robust governance, stakeholder trust and interoperability. In addition, ensuring that data spaces scale effectively across multiple sectors, each with different standards and needs, will require support and ongoing collaboration. • Standardisation and interoperability: Developing and adopting common standards across data spaces is needed. Standards should govern data formats, interfaces, and communication protocols to ensure that different systems can seamlessly exchange and interpret data. Stakeholders should actively participate in the development of European and international standards that ensure interoperability. Moreover, consistent data quality guidelines are crucial to maintain reliability in multi-sector data exchanges. Encouraging alignment with recognised European and global bodies (e.g., CEN-CENELEC, ISO) can further enhance compatibility and scalability. • Data governance frameworks: o Implement clear data governance models that define the ownership, access rights, and responsibilities of different stakeholders in the data space. Provide model contractual agreements that allow decentralised datasharing to have more concrete rules of engagement including usage control policies. Address privacy and intellectual property concerns by integrating robust mechanisms for data anonymization and secure authentication, ensuring compliance with GDPR. o Multilayered oversight: Consider promoting neutral intermediaries formed by multi-sectoral stakeholders (manufacturers, recyclers, regulators, consumer groups …), to oversee data sharing rules, resolve disputes and manage evolving standards. Define the role of data intermediaries (as envisioned in the DGA) to ensure neutrality. Ensure there are dispute-resolution and auditing mechanisms, for instance, with an intermediary body that can log interactions and monitor if policy or contractual breaches occur. • Financial and technical support: o The IT development of data spaces needs to consider the ability of SMEs with limited investment capacity and often outsourced software developers to connect to Data Spaces. It is recommended for public investments in data spaces initiatives to integrate no-code SME connectivity options. o Financial support in particular for SMEs to help modernise IT systems and integrate DPPs (e.g. targeted grants, loans or tax-credits, leveraging of public procurement). Encourage pilots through public procurement that showcase results from data-driven circular strategies. o The deployment of a data space can be too complex for most IT parties as these rely on new IT technologies, unless it is streamlined and guidance and training are provided Training and resources to stakeholders is necessary to ensure they have the skills and knowledge to effectively participate in and benefit from interoperable data spaces. 54 • Innovation exploitation: Implement initiatives and funding to help promote that the data in data spaces is used for innovative and circular business applications (e.g. resource matching, eco-design feedback loops, predictive maintenance). • Adaptability throughout implementation: Policymakers must work closely with industry and technology experts for modifying data spaces as needed when they are implemented. Integrating a feedback loop for continuous improvement of data spaces functioning to ensure they can deliver their expected benefits. Monitoring and impact assessment tools (e.g., KPIs for waste reduction, resource recovery rates) should be built in from the outset, allowing real-time adjustments and fostering transparency about the environmental and economic results delivered by Circular Applications Data Spaces. To conclude, Circular Applications Data Spaces have the potential to be instrumental for advancing circular economy goals in the EU. However, for this to happen, it is necessary to adopt clear standards for interoperability, robust data governance and well-targeted support for successful implementation. By ensuring transparency in oversight, ensuring auditing measures, and maintaining a continuous process of improvement, these data ecosystems could potentially scale and function securely, generating outcomes such as more efficient resource recovery, deeper supply chain collaboration, and a verifiable reduction in environmental impact. 55 CONCLUSIONS In this section we outline the key takeaways from each policy brief including the recommendations put forth for EU policymakers regarding the development of the DPP system under the ESPR regulation and related regulations. Policy Brief 1: How digital product passports can contribute to science based circular economy targets This policy brief outlines how Europe’s current linear economic model is unsustainable, driving environmental degradation, resource insecurity, and economic inefficiencies. Transitioning to a circular economy offers significant environmental and economic benefits, potentially saving €600 billion annually and reducing resource extraction and waste. However, existing EU policies predominantly focus on recycling (cycle pillar), overlooking critical aspects such as resource reduction (narrow pillar), prolonging product lifespan (slow pillar), and material regeneration (regenerate pillar). To effectively realize circular economy benefits, comprehensive policy actions addressing all four pillars, underpinned by binding, science-based targets, are urgently required. The brief positions Digital Product Passports (DPPs) as critical tools to fill current data gaps, offering precise and timely product-level data essential for monitoring circular economy targets. Recommendations for Policymakers: • The European Union should ensure that circular economy policies across legislative files and standards coherently address all four pillars of circularity to avoid fragmented and ineffective strategies. • The European Union must integrate concrete climate change objectives in circular economy policies, to ensure that CE policies can effectively contribute to mitigating climate change. • The European Union must set binding, overarching material footprint reduction targets that are based on sustainable levels of resource extraction and consumption, as well as GHG emission reduction targets that are aligned with a 1.5-degree warming scenario. The upcoming Circular Economy Act should be used as the legislative vehicle for these targets. • The European Union must ensure that all circular economy policies define actions and that actions coherently address all four pillars of the circular economy. Actions should be aligned with quantitative targets and present a balanced mix of policy tools. The Circular Economy monitoring framework should integrate all pillars of the circular economy. Each objective must be linked to relevant indicators to assess progress against the objectives. • The Circular Economy monitoring framework have a sectoral declination, focusing on specifying progress at minimum at product group level (e.g. Energy related 56 Products, textiles) and where possible also per product type (e.g. washing machines, garments), based on aggregating data from DPPs of products placed on the market per product type. • The European Commission and Eurostat should explore how data generated that can be contained in DPPs and exchanges on an automated basis to other IT systems, can be used to complement existing datasets or provide entirely novel direct primary materials data. • The European Union should define clear methods for companies on how to collect high quality primary data and incentivize their use over secondary data. • The European Union should ensure that the DPPs are closely monitored and controlled, and that recommendations are provided to companies to improve the quality of their data, and sanctions effectively applied. Policy Brief 2: Ensuring chemical traceability with the Digital Product Passport This brief addresses how the DPP can improve the traceability of chemicals in products, and what the necessary conditions are for the DPP to deliver on this objective. The paper outlines significant gaps in chemical traceability within EU supply chains, highlighting substantial health and environmental risks posed by hazardous substances present in consumer products, notably recycled materials. Existing chemical tracking systems, such as the SCIP database or REACH regulation, remain incomplete and fragmented, impeding transparency and hindering informed decisions regarding chemical management. The DPP mandated under the ESPR regulation presents a transformative opportunity for comprehensive chemical transparency, enabling traceability throughout the product lifecycle, reducing harmful chemical usage, and promoting safer substitutions. Yet, critical challenges remain, including confidentiality concerns, unclear definitions of exempted substances, and the necessity of integrating DPP data effectively with existing databases. Recommendations for Policymakers: • Policymakers must ensure that the necessary information is collected and shared: o Information requirements must enable the identification of all chemicals present in products o The DPP must ensure that information on chemicals remains accessible along the life cycle of the product o When adopting Delegated Acts of the ESPR, policymakers should strategically prioritise developing information requirements for intermediary product groups, to build the knowledge base necessary to set information requirements on final products and reduce costs of chemicals traceability for companies across supply chains. 57 o The EU Commission must ensure that the DPP is integrated with other chemical databases to facilitate information reporting and sharing. The automated data exchange setups of DPPs need to be utilised in making these linkages, so as to enable low-cost and useful chemicals information management. o Policymakers must align the definition of confidential business information with the EU Regulation on Persistent Organic Pollutants to protect human and environmental health o Policymakers must add new due diligence requirements to document and record important characteristics of WEEE containing CRMs. • Policymakers and public authorities must ensure that the information is indeed used. The use of DPP chemical data must encourage the phase-out of hazardous substances and their replacement with safe and sustainable chemicals. To achieve this: o The DPP must be designed to facilitate access to safety information for workers and ensure that problematic legacy chemicals are phased-out from circular value chains. To achieve this, industrial actors must implement tools and infrastructures to incorporate the use of DPP information in their processes. Workers should be trained and empowered to identify and safely discard materials that contain substances of concern when collecting used parts or secondary materials. o The DPP must enable consumers to identify products with safe and sustainable chemicals, and chemicals with substances of concern to facilitate consumer choice. The DPP must also facilitate consumers’ access to safety information. o The DPP must have differentiated access for public data and additional safety data for all chemicals, going beyond substances of concern, especially for agencies and experts carrying out environmental and human safety studies and screening of chemicals in products. Here also automated data exchange is of significance on a secure basis, to enable speed and lower the cost of chemicals assessments. o Policymakers and Public authorities must use the DPP to monitor the use of chemicals in products to improve the regulation of chemicals. This information should also be available to researchers and civil society. o Market authorities must use the DPP to reduce the entry of nonconforming and dangerous products on the EU market. Any missing data should be considered as a lack of conformity. • Chemical traceability is a key foundation to effective chemical regulation, but cannot replace mandatory restriction and substitutions of substances of concern. The planned revision of REACH should ensure that hazardous substances do not enter the value chain. Product regulations should also ensure that products are safe for both consumers and the environment, and that their production and processing does not put workers and the environment at risk. 64 1.2.2. Workshop discussion held by dss+ and Eco-wise with consumer associations Altroconsumo, OCU and DECO PROTeste at the CircThread GA in Porto, Portugal, June 2024 Questions asked of Consumer Associations • What would be the barriers or concerns to consumers “giving” data to a DPP? • Is there a way to incentivize consumers to share data? • What role does a DPP really have for consumer? • What benefit models are there for consumers to be part of the circular economy journey? • Why would a consumer want to provide their product usage feedback? Or utilise the platform for repair signalling? Or other interactive services? Incentives discussed to motivate consumers to share data Having identified the key barriers, a number of ideas being tabled of ways to address these: • Register the product on a DPP, not the consumer to retain anonymity • Gamification of DPP – earning points or tokens that can be redeemed for sharing data. But data needs to be verified, or it risks being abused • Marketing campaign to raise consumer awareness of DPPs when purchasing the product so it becomes something they are aware of from the start of the ownership time (need for labels or communications online or in-store at point of purchase) • Endorsement by consumer organisations – direct consumer to use the DPP with links on their website to DPP portals, showing where they can find the barcode they need to scan etc… • Include registration on the DPP at the same time that a consumer registers a product’s guarantee to make it quick and simple without adding administrative burden. This would need supporting data to be included by manufacturers on product packaging, in-store information and online • Consumer organisations might be able to validate information uploaded by their members to help provide confidence in the accuracy of data shared. This can be combined with existing insights that consumer organisations already have on brands from other complaints or issues they’re addressing • Having an expert review by OCU of product could be aspirational for manufacturers to be able to share on the DPP 1.2.3. Durability Index Overview The Durability Index has 3 additional criteria of: 1. Resistance of key product or its components to wear/stress including corrosion 2. Maintenance and upkeep – based on how a product is used in its nominal functional state. This includes the ease of access to information on maintenance procedures, the quality and level of detail of the information on maintenance procedures, and the ease with which maintenance procedures can be carried out 3. Quality and warrantee which also include not just how long a manufacturer offer a guarantee for but also aspects such as having a continuous improvement system that looks at breakdown rates 65 1.2.4. Possible terminology that is more consumer-friendly Industry/manufacturers’ term What it really means Alternative consumer-friendly term End of life Cannot be repaired or it is not commercially viable to do so Ready for recycling Disposal Need to be recycled and NOT put in landfill or bin Ready for recycling Remanufacture Suitable to be rebuilt by replacing part for resale/reuse Rebuild and resell Recycle Send to be dismantled by a registered facility so that the components can be processed back into the materials they were made from to make new items Recycle back to new Expert engineer Any repairer endorsed or trained by a manufacturer, specialised school or trade program to repair products using approved parts Approved repairer 1.3. Annex to Policy Brief #4 on Circular Applications Data Spaces References to topics discussed • https://datos.gob.es/en/blog/interoperable-europe-act • https://hollandcircularhotspot.nl/case/excess-materials-exchange-the-digitalplatform/ • https://digitalfactoryalliance.eu/data-sovereignty-in-zero-defect-manufacturing/ • https://cordis.europa.eu/project/id/825030 • https://internationaldataspaces.org/make/projects/ • https://digital-strategy.ec.europa.eu/en/library/staff-working-document-dataspaces • https://www.circularise.com/blogs/data-policies-in-the-eu • https://www.geograma.com/en/blog/common-data-spaces-their-usefulness-andcurrent-situation-in-the-european-union/ • https://gs1.eu/activities/new-eu-data-acts/ • https://www.ifri.org/en/papers/troubled-reorganization-critical-raw-materialsvalue-chains-assessment-european-derisking#:~:text=The%20risk%20for%20Europe%20is,resilient%20and%20secur e%20supply%20base • European Electronics Recyclers Association (EERA (2022). Towards an EU WEEE Regulation: the position of the European Electronics Recyclers Association. https://static1.squarespace.com/static/6273d6aab17e87401893aefc/t/62c4b4 31fab29a4a04bb1c29/1657058354428/EERA+- +Towards+EU+WEEE+Regulations+-+Published+January+2022.pdf • Koppelaar, Rembrandt H. E. M., Sreenivaasa Pamidi, Enikő Hajósi, Lucia Herreras, Pascal Leroy, Ha-Young Jung, Amba Concheso, Radha Daniel, Fernando B. Francisco, Cristina Parrado, and et al. (2023). "A Digital Product Passport for Critical Raw Materials Reuse and Recycling" Sustainability 15, no. 2: 1405. https://doi.org/10.3390/su15021