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Writer's picturePeter Bjellerup

How did the EU select the initial industries to be required to provide digital product passports?

Updated: 3 days ago

"Why not food?" is a completely justified question. As is "why garments & footwear?".


In the coming years, when the European Union introduces requirements for digital product passports to accompany products sold in the Union, the intention is to apply the regulation initially to a limited number of industries (still a moving target):


  • Batteries (a separate, but parallel directive)

  • Garments and footwear

  • Iron and steel

  • Electronics and ICT

  • Furniture

  • Chemicals, detergents and paints

  • Aluminium

  • Tyres and lubricants

Why these industries were selected to be first in line, we don't know for sure. But we have some hypos that we'd like to present. What do you think? Or maybe you know, even? Please share your thoughts in a comment.


First of all, we can't identify a single characteristic in common for them all. Rather, there seems to be a mix of characteristics weighing in here. Let's have a look at which they may be:


  1. Environmental impact – It would be surprising if the legislators didn't try to go first with industries having a major environmental impact. After all, the overarching purpose of digital product purpose is environmental. The inclusion of batteries, chemicals, tyres, plastics and steel & iron signals that environmental impact indeed is a major factor in making the selection.

  2. Relatively uncomplicated – If environmental impact were the sole reason, there are additional industries that should be included, but which would be even more complicated for breaking the ground. Petrol and oil, for example.

  3. Relatively low level of existing targeted regulation – Without suggesting that these industries are unregulated, other potential candidates like pharmaceuticals or food and agriculture are already regulated and may have been considered in less need of additional environmental regulations. Or, maybe the exclusion of agriculture is simply tactical. It seems as if the surest way to cause a blockage in passing EU regulations is to touch agriculture, an industry full of vested interests, national pride and angry farmers, prone to protest actions.

  4. Social responsibility issues? – Throwing a curved ball here, could the inclusion of garments & footwear and electronics & ICT have something to do with them having had issues with child labour and illegal mining of sensitive minerals in some countries of origin?

Please remember that this is just a reasoning about the sequence of introduction of digital product passes, not a matter of which industries to be covered. The stated intention is for ALL industries to be required to provide digital product passes – over time. So, if your industry isn't on the list, you'll just get additional time to prepare and the luxury of perhaps avoiding some teething pains of applying the regulation.


Do you have solid knowledge of the selection criteria for the industries? Please share.


We'd greatly appreciate your thoughts on our hypos. Do you think they have merit or are they just wild speculations?


Why the industries chosen to be first in line for digital product passports were selected by the European Union, we don't know for sure. But we have some hypos that we'd like to present. What do you think? Or maybe you know, even? Please share your thoughts in a comment.  First of all, we can't identify a single characteristic in common for them all. Rather, there seems to be a mix of characteristics weighing in here. Let's have a look at which they may be:  Environmental impact – It would be surprising if the legislators didn't try to go first with industries having a major environmental impact. After all, the overarching purpose of digital product purpose is environmental. The inclusion of batteries, chemicals, tyres, plastics and steel & iron signals that environmental impact indeed is a major factor in making the selection. Relatively uncomplicated – If environmental impact were the sole reason, there are additional industries that should be included, but which would be even more complicated for breaking the ground. Petrol and oil, for example.  Relatively low level of existing targeted regulation – Without suggesting that these industries are unregulated, other potential candidates like pharmaceuticals or food and agriculture are already regulated already and may have been considered in less need of additional environmental regulations. Or, maybe the exclusion of agriculture is simply tactical. It seems as if the surest way to cause a blockage in passing EU regulations is to touch agriculture, an industry full of vested interests, national pride and angry farmers, prone to protest actions. Social responsibility issues? – Throwing a curved ball here, could the inclusion of garments & footwear and electronics & ICT have something to do with them having had issues with child labour and illegal mining of sensitive minerals in some countries of origin?
Batteries, an obvious area of environmental concern

Credit: mark3mark on iStock

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