Digital Product Passport, our point of view. Paper on DPP content based on TRICK NEEDs

Introduction

The TRICK project, funded by the European Union, actively supports the goals of the Digital Product Passport (DPP) to promote circularity, sustainability, transparency, and traceability in the textile sector. The introduction of legislative requirements under the Eco-design for Sustainable Products Regulation (ESPR) marks a significant shift for European industries, offering new opportunities to improve the sustainability and traceability of products while enhancing consumer confidence. However, these new regulations also present considerable challenges, especially for small and medium-sized enterprises (SMEs), requiring a coordinated approach to ensure that the entire textile value chain can comply with the new requirements without compromising competitiveness.The TRICK project aims to facilitate data exchange across the textile value chain in an interoperable manner, promoting open standards and ensuring that the requirements imposed are proportionate to the capabilities of economic operators, with a particular focus on SME needs. This vision aligns with the paper prepared by Euratex, with which the TRICK project coordinates efforts to support the development of a robust and efficient system for the DPP.

Information Requirements for the DPP

The TRICK project advocates the inclusion of information in the DPP that meets legal requirements without compromising the confidentiality of business information. The core data should include details related to product durability, reusability, recyclability, recycled content, and compliance with other regulations. The collection of this data must be scalable and adaptable, starting with existing information and expanding the scope over time to accommodate future requirements.
For six key intermediate production stages (recycling, fiber production, spinning, weaving/knitting, finishing, final product assembly), the TRICK project proposes implementing traceability practices to provide essential information, such as manufacturing location, product type, and recyclability. These data points are necessary to meet ESPR compliance requirements and promote material circularity throughout the product's lifecycle.

Confidential Information Management

Protecting confidential business information is a crucial aspect of maintaining the competitiveness of European companies. The TRICK project promotes the adoption of data-sharing protocols that safeguard sensitive information while allowing access on a "need-to-know" basis. This approach ensures that companies can protect their intellectual property and business relationships while complying with the information requirements mandated by the DPP.
To address the confidentiality concerns, the TRICK project supports the establishment of standards for data security and confidentiality that build on existing industry practices. This includes clarifying when the obligations of the DPP end and specifying how long the information must remain accessible, particularly regarding the recycling phase.

User-Specific Information Tailoring

The TRICK project recognizes the importance of tailoring the information provided by the DPP based on the needs of different users (e.g., consumers, market surveillance authorities, recyclers). Information should be selectively disclosed, with only relevant data being made available to the various stakeholders. This selective approach ensures that sensitive information is not unnecessarily exposed while still meeting transparency requirements.
In the supply chain, companies should be able to decide which actors can access specific information, based on established business relationships or agreements such as non-disclosure agreements (NDAs) or payment-based services. The TRICK project’s approach aligns with the need for flexible data-sharing mechanisms that accommodate diverse needs within the value chain.

Data Exchange Standards and Interoperability

The TRICK project strongly supports standardization efforts aimed at ensuring interoperability and data portability across the textile supply chain. Given the fragmented nature of existing data exchange systems, there is a need to establish open international standards that enable seamless data sharing. The project has contributed to developing data exchange formats related to traceability and sustainability, specifically through extensions to the eBIZ framework, which facilitate a comprehensive approach to information management in the textile sector.
To ensure that the DPP implementation benefits all stakeholders, including SMEs, the TRICK project advocates for the introduction of flexible data models that can accommodate both mandatory and optional information, depending on the user’s role and data needs. This approach aligns with recommendations for a phased implementation that allows companies to gradually adapt to new requirements.
This approach will also grant the benefits from the competition of different IT solutions on the market, which would be enabled and requested to share the data using the same models and standards.

Challenges and Opportunities for SMEs

The TRICK project acknowledges the various challenges associated with implementing the DPP, including issues related to data quality, technological infrastructure, and the financial burden on SMEs. The project proposes several measures to help overcome these challenges:

• Phased Implementation: Start by gathering accessible product information that is already available and gradually expand the scope of data collection to include more complex information as companies build capacity.
• Support Mechanisms for SMEs: Provide SMEs with access to financial incentives, training programs, and tools that help them manage data collection and compliance requirements efficiently. Supporting initiatives such as pilot projects, industry workshops, and collaborative efforts with IT providers can facilitate a smoother transition.
• Confidentiality Protections: Introduce clear protocols for the disclosure of sensitive business information, ensuring that it is protected under a “need-to-know” basis to maintain the competitiveness of European companies.
• Standardization and Interoperability: Develop cross-sector and sector-specific standards for data exchange, ensuring that the standards are proportionate to the capabilities of companies and allow for scalable implementation. The use of established standards like eBIZ and the TRICK project's contributions to traceability frameworks can serve as a foundation for these efforts.

Recommendations for the Implementation of the DPP

1. Gradual Rollout: Introduce the DPP in stages, beginning with accessible data and expanding the range of required information over time. This staged approach helps identify potential problems early and allows companies to adapt incrementally.
Data Granularity: The adoption of DPP at batch level is the only solution to grant that information can be controlled and inspected
2. Immutability: The adoption of Blockchain would be advisable to grant immutable data and to enable the identification of their authors through the value chain, increasing transparency.
3. Sector-Specific Guidelines: Develop implementation guidelines tailored to the textile industry, which provide clear instructions on creating interoperable solutions. This includes defining data requirements based on product categories and outlining the procedures for collecting and verifying information.
4. Interoperability and IT Infrastructure Development: Encourage the development of data exchange systems that support interoperability across multiple platforms, avoiding monopoly conditions that could arise from the dominance of a single DPP solution provider. Ensure that the chosen data formats, such as GS1 EPCIS, UN/CEFACT, and eBIZ, can accommodate the specific needs of the textile sector.
5. Data Security and Confidentiality Standards: Establish guidelines for managing sensitive information, ensuring that the DPP implementation does not compromise business confidentiality. This includes creating ontologies and dictionaries for product features and production processes to standardize data representation.
6. Support for SMEs: Provide long transition periods, financial support, and training to help SMEs comply with the new requirements. It is essential to recognize that SMEs often lack the resources of larger companies and may face higher relative costs for compliance.

Addressing Technological and Data Quality Challenges

The implementation of the DPP involves substantial data management efforts, including data collection, validation, and exchange. TRICK recommends the adoption of technological solutions that can automate data collection and ensure quality assurance. The use of decentralized databases, where each supply chain actor is responsible for its own data management, can help protect business information while ensuring data integrity.
To address inconsistencies in data quality, the TRICK project suggests the development of quality control protocols and training programs for suppliers. This will help ensure that data is reliable and meets the necessary standards for regulatory compliance. Additionally, harmonizing data language and terminology across the industry will reduce ambiguities and facilitate smoother data exchange.

IT Infrastructure and Data Carriers

The TRICK project recommends the adoption of a hybrid approach that combines physical and digital data carriers for the DPP. Options such as RFID tags or QR codes embedded directly in the product could ensure that recyclers and other stakeholders can access the information throughout the product's lifecycle. By considering the specific requirements of the textile industry, such as the durability of data carriers and their interaction with physical products, the DPP can be made more practical and reliable.

Conclusion

The TRICK project is committed to supporting the successful implementation of the Digital Product Passport within the ESPR framework. By aligning with the goals of Euratex and other stakeholders, the project aims to foster a more sustainable, transparent, and efficient textile industry. Through collaborative efforts, standardization, and support for SMEs, TRICK seeks to enable the entire textile value chain to embrace the DPP as a tool for driving circularity and sustainability.

CONTACT PERSON & EMAIL ADDRESS: 

• Mauro Sampellegrini - SMI (email)