The European Union “Ecodesign for Sustainable Products” (ESPR) legislation is a package of measures intended to increase the sustainability of products placed on the EU market by improving their circularity, energy performance, recyclability and durability. Rolling out under a series of industry specific “delegated acts” over the next decade, it will affect batteries, textiles, electronics, furniture, chemicals, plastics and packaging.
The ESPR introduces “Digital Product Passports” (DPP) - an electronic collection of information about a specific product. The DPP enables consumers, manufacturers, and authorities to make informed decisions related to sustainability, circularity and regulatory compliance. Depending on the industry, the EU may require a DPP to be maintained at one of three different levels: “Model Level”, “Batch Level” and “Item Level”. This article explains the differences between these terms and explores the benefits and drawbacks of Digital Product Passports at each of these levels.
Model, Batch vs. Item Levels Defined
Just like a travel passport consists of a unique passport number and accompanying facts about the individual (name, photo, address etc.), a Digital Product Passport is really just a product identification code and accompanying digital information about a particular product - such as its manufacturer, its materials and components, product photos, its recycled content levels, its carbon footprint etc.
But let’s go back to that “identification code” for a product. If you have two identical products in either hand, you might expect that the Digital Product Passport identification code for both items would be different - in the same way your travel passport number is different to mine.
But in fact, the ESPR legislation acknowledges that this might not be the case. It defines three different “levels” of identifier granularity - “Model” level, “Batch” level and “Item” level. Here are the EU definitions for each:
- ‘Model’ refers to a version of a product of which all units share the same technical characteristics relevant for the ecodesign requirements and the same model identifier
- ‘Batch’ refers to a subset of a specific model composed of all products produced in a specific manufacturing plant at a specific moment in time
- ‘Item’ refers to a single unit of a model
Why aren't Digital Product Passports always at item level?
In a nutshell, the EU is considering different levels due to one reason: cost vs. benefit. In the EU’s own words in the ESPR regulation text: “To avoid costs for companies and for the public that are disproportionate to the wider benefits, the digital product passport should be specific to the item, batch or product model, depending on, for example, the complexity of the value chain, the size, nature or impacts of the products considered. The impact assessments carried out when preparing the delegated acts setting ecodesign requirements should analyse the costs and benefits of setting information requirements through digital product passports at model, batch or item level.”
It is easiest to mark an entire product line with a single identifier - in fact the industry already does this today with the retail barcode number - the GS1 Global Trade Item Number (GTIN). When every product label is the same, you can use cheap mass-printing techniques to reduce the cost of labels.
When the identifier on a product could vary, then you need variable printing and marking capabilities. Today, many products have a “batch” or “lot” number printed on them, usually as a human readable marking:
Batch numbers are present on most products for quality control and traceability
This number would change with each production run. Usually, the production line has some sort of printing or marking capability which achieves this.
If we want “item level” identification, where the code would change with every single item produced, then of course you also need variable printing capabilities. But often the technical requirements are even more challenging, especially in high speed environments producing low-cost goods, as the output of the printing/marking step must change each time.
Serial numbers are often assigned to durable, high value goods such as electronics
What Digital Product Passport data requirements can “Model” level meet?
A “Model” level Digital Product Passport can only contain data that holds true for every single instance of the particular product, regardless of where and when it was manufactured and the specific supplier material that went into it. Here is a list of ESPR data points where a model-level DPP would be appropriate:
- Whether a product can be repaired, maintained, upgraded or refurbished
- Whether a product can be recycled, reused or remanufactured, and whether its raw materials can be recovered
- Expected performance and durability parameters for a product
- How energy or water efficient the product is during operation
- The ingredient list of a product, including substances of concern
- Photos, measurements and other descriptions of the product common across instances
What Digital Product Passport data requirements can “Batch” level meet?
A “Batch” level Digital Product Passport can contain any data that a “Model” level one can. But it can also hold data that can vary on the basis of where and when an item was manufactured and the specific material that went into it.
So a Batch level DPP can hold all ESPR data points that a model-level one can, plus the following:
- The exact manufacturing party, manufacturing location and manufacturing time
- The exact raw materials and that went into the product, including the source supplier of these raw materials
- An accurate carbon and water usage footprint that reflects where and how the product was manufactured and the exact supplier materials that went into it
- An accurate calculation of the percentage of recycled materials that went into the product or its packaging (if it varies by manufacturing site and supplier materials used)
A “Batch” level DPP cannot distinguish between lifecycle events that happen to a specific product instance.
What Digital Product Passport data requirements can “Item” level meet?
An “Item” level Digital Product Passport can contain any data that either a “Model” or “Batch” DPP can. But information at “Item level” can also account for what happened to just this individual product instance after it has left the factory. Examples of some ESPR data points in this category include:
- Specific component parts that were installed into an item
- Post-manufacture distribution journey and point of sale
- Whether a specific item is refurbished, reused or remanufactured
- Current state of an item: e.g. expected lifetime, performance or durability for a second hand battery
- Return or reuse count
- Repair, accident or harmful/significant event history
- Historical metrics and sensor data pertinent to a specific item
Summary
The EU’s Ecodesign for Sustainable Products Regulation (ESPR) introduces Digital Product Passports (DPPs) to enhance product sustainability and circularity. DPPs store product-related data and can be implemented at three levels:
- Model Level: Applies to all identical units of a product, covering common attributes like repairability, recyclability, efficiency, and ingredient composition.
- Batch Level: Tracks variations within manufacturing batches, including production location, supplier materials, and batch-specific environmental footprint.
- Item Level: Provides the most granular tracking, covering an individual product's components, lifecycle events, refurbishments, and usage history.
The exact level required will be specified in industry specific acts, which will balance public interest with the cost and complexity of higher granularity data.
If you’d like to learn more about Digital Product Passports and the technology and standards available to collate and expose data at any of these levels, check out the TrackVision Digital Product Passport solution page or contact TrackVision today at https://trackvision.ai/contact