Latest Developments on the EU ‘Green’ Product Passport Front

In the February issue of Authentication & Brand News™, we asked whether EU digital product passports (DPPs) could double as anti-counterfeiting devices, in addition to their primary role of gathering information about a product and its supply chain in order to support the transition to a circular economy.

Since then, work has been progressing towards the roll-out of DPPs on priority product groups. This article provides an update on that progress, as well as addressing different concerns raised by stakeholders with regard to the DPP regulation. We then give a few examples of recent initiatives by authentication and traceability providers to align themselves with the DPP, thereby demonstrating the significant impact DPPs could have in this sector.

Standards and pilots

Work is now underway to develop technical standards in line with the DPP regulation. The bodies jointly responsible for doing this are the European Committee for Standardisation (CEN) and European Committee for Electrotechnical Standardisation (CENELEC).

Their work is initially focused on batteries, textiles, and electronics, and will continue until the end of 2025. The solutions based on the results of this work will then be extended to most European products by 2030.

In the meantime, several proofs of concept aimed at preparing the ground for concrete technical solutions are being carried out.

For example, a consortium of organisations has joined forces on a pilot study to create and test a DPP for textiles that can be used to electronically register, process, and share product-related information between supply chain partners, authorities, and consumers.

A key part of the project is the development of a common protocol enabling sharing of data between different organisations. With that in place, the pilot will test the system by tagging selected garments from apparel brands Kappahl and Marimekko. The garments will be tagged during production with an ID linked to a QR code that will allow product information to be accessed instantly using a mobile device.

The technology underpinning the project is provided by TrusTrace, with other partners in the consortium including the Swedish Institute for Standards, GS1 Sweden, TEXroad Foundation, Circularista, 2bPolicy, Rudholm & Haak, Aalto University, and Trimco Group.

‘Our goal is to effectively test how a DPP can function in practice – and prepare for future implementation,’ said TrusTrace co-founder and Chief Executive Shameek Ghosh.

Overlapping and security concerns 

While the DPP regulation focuses on the circular economy and environmental and sustainability issues, stakeholders have flagged the need to consider the potential overlap of DPP with other regulations.

For instance, traceability schemes are already in place at EU or member state level, eg. on tobacco products, pharmaceuticals, medical devices, and alcoholic beverages. And other EU initiatives, such as the EU Intellectual Property Office Blockathon Infrastructure (a blockchain-based system interconnecting individual systems to ensure product authenticity throughout entire supply chains), could also overlap with the DPP.

It is therefore important for the DPP to seek convergence or alignment with these other initiatives. Otherwise, it would be extremely cumbersome for a manufacturer to have to manage and mark each product with multiple ‘passports’ (not to mention confusing for consumers).

For these reasons, a clear wish was expressed by EU representatives at a recent series of CEN/CENELEC expert meetings, to develop a generic and overarching framework of interoperability to cover all existing data models and traceability ecosystems – even extending to the food and pharmaceutical sectors, which are currently explicitly excluded from the scope of the DPP regulation.

Another concern with DPP is that it lacks provisions for ensuring the security of the 2D barcode required on each product. While a barcode is an excellent device for automated data capture, a copy or recreation of that barcode would connect the user to the same DPP – or even to a fraudulent, ‘DPP-like’ website.

Solution providers in the authentication industry have flagged the DPP’s lack of security considerations as a major weakness that needs addressing, given that counterfeiters will easily exploit this loophole. They warn that this type of fraud already exists, and that the massive use of 2D barcodes linked to the DPP will only exacerbate the situation.

Their advice to the EC is to carry out a stakeholder consultation exercise to assess the overall risk of fraud within each product group. If the risk is considered low, the regulation could allow the use of non-secured barcodes. If it is ‘reduced’, the regulation could provide guidance on acceptable authentication approaches. And if the risk is high, then solutions involving third-party certification of selected authentication systems – as well as certification of the suppliers of those systems – should be required.

These various concerns will likely be addressed by the CEN/CENELEC joint committee throughout the coming year; therefore it will be important for the authentication industry to stay abreast of developments.

Supplier alignment with DPP

Finally, let’s turn to two recent initiatives by solution providers to align their offerings with the DPP regulation.

Starting with Germany-based Polysecure, this company has developed TrackByStars®, an in-product marker technology for uniquely identifying and tracking a wide range of products.

The technology uses high-contrast fluorescent particles (tracers) mixed into materials such as plastics, paint, resins, and adhesives, before the processing stage. The particles create a random 3D pattern – or ‘fingerprint’ that is unique to each unit of a particular product. The particles only becomes visible when excited by a special light.

According to the company, TrackByStars meets the requirements for unique identifier technology, which is mandatory for all DPPs. The random patterns are not copyable, easily readable, as well as being practically invisible and robust against damage, which common technologies such as QR codes or watermarks do not offer, it claims.

TrackByStars enables permanent, unambiguous identification, even for complex and heavily stressed products, so is ideally suited to DPPs, says Polysecure. For batteries, furniture, textiles, packaging and other products, the marker can be used as a unique identifier by storing it in a database.

‘The code is read via a handheld detector. We are currently working on providing a robust solution for industrial environments as well, for example for moving product streams, or in a waste sorting facility. Once we succeed in this, the application possibilities will be much broader,’ advised CEO Jochen Moesslein.

The second initiative comes from Avery Dennison, which has launched its Digital Product Passport as a Service (DPPaaS). Burton Snowboards is the first customer to use the new service, which comprises consultancy, hardware, software, digital ID technology, physical labels, and support services – providing brands with a holistic approach as they prepare for DPP, claims the company.

DPPaaS is part of Avery Dennison’s more extensive digital solutions portfolio, which connects the physical and digital worlds through its intelligent labelling and atma.io connected product cloud platform. Via atma.io, Avery currently tracks 30 billion items across the supply chain for global brands, capturing information that the company says is vital for DPP, including carbon footprint data, origins of materials, and reuse instructions.

And there will no doubt be more initiatives to come.