Passport Data Requirements Reach Into Substances of Concern and End-of-Life

Data requirements for Digital Product Passports will vary by product group, but are expected to cover material composition, substances of concern, environmental performance indicators, durability and end-of-life information. Manufacturers and importers of electronics are advised to prepare for collection covering product identifiers, material origins and sustainability metrics, against Ecodesign criteria of durability, reparability, recyclability and carbon footprint.

End-of-life information is the field that most changes design conversations, because it is the one written for a reader who is not the customer. A recycler scanning a device wants to know what is inside it, which parts contain something hazardous, and how to separate them — questions nobody asks during development and which have answers determined entirely by decisions made there.

Substances of concern is the field with the longest tail of work. It is not satisfied by a supplier declaration filed once, because the list of substances of concern changes and a product that complied when it launched may not comply two years later without anything about it having changed. Keeping that current is an ongoing obligation rather than a launch task, which is a different kind of commitment from most of what a hardware team is used to carrying.