Chemical´s digital blueprint in a circular economy
On the one hand, transparency about products is a “must have” in a circular economy, on the other, chemical companies are extremely protective of their know-how and confidential information, which makes the industry lean towards a need-to-know basis approach rather than in the direction of the open access policy makers are after for the sake of the consumers, when it comes to communicating about substances along the value chain.
The chemistry behind:
An introduction to the product passport
Digital product passport (DPP) is to be one of the chosen tools for implementing and scaling the circular economy. DDP is key to enhance the traceability of products and their components, it is meant to track the origin of all materials and components used in the manufacturing processes of everyday consumer goods.
The requirement of a digital product passport is present across all directives and regulations of the EU Green Deal and Circular Economy Action Plan.
To enable sustainable procurement a DPP is also expected to provide information about regulative compliance, such as the RoHS (Restriction of Hazardous Substances) and REACH (Registration, Evaluation, Authorization and restriction of Chemicals) Directives.
Re-considering the risk management in the process
REACH was set up to take into account the potential risks during the entire life cycle of chemicals, including the waste phase, but, in practice, the focus has been on the production and use stages of substances. Circular and bio-based chemistry initiatives interlink with the REACH regulation. The thing is, the more circular de economy becomes, the longer the chemicals will stay in use, making it more difficult to remove those that are problematic.
One part of the solution has to do with substituting harmful substances and therefore information of product compositions is key to address this matter.
Waste is faster becoming a raw material in processes and a commodity to be traded, so we need to ensure that it has been processed in such a way to create a safe product. But, at this point in time waste is exented from REACH chemicals law. Issues emerge when discuardded products contain substances which have since been restricted or controlled trough this law. This creates a problem at the door of the recyclers and coverters on how to deal with this substances. The lack of information about the specific composition of the waste at the recycling facility greatly affect the ability of recyclers to comply, creating legal uncertainty.
Will legislation move towards an hybrid digital solution?
Coming back to the flagged concerns around who gets to see which kind of information and the direction the industry is pointing towards, the use of other tools or solutions to reach a compromise moving forward is not to be ruled out.
Industry is showcasing the benefits of early adopters pilot’s using blockchain and encryption digital information sharing technologies in becoming integral to the development of digital product passport.
Moreover, looking at the information requirements for substances of concern and the DDP, the Eco-design for Sustainable Products Regulation (ESPR) may even provide existing reporting obligations redundant, in favour of more tailored and digital solutions. These legislative changes will take years and while the ESPR will be implemented by product group and may not always result in delegated acts and the existing obligations are in force and wide in scope. Widdening the Ecodesign Directive beyond energy-related products so as to make the Ecodesign framework applicable to the broadest possible range of products and make it deliver on circularity is part of the Circular Economy Action Plan.
And that is one of the reason why having a saying at the regulatory component of the three-part roadmap is such an enabler for the Transition Pathway of the chemical industry.
Legislations to follow:
REACH: Registration, Evaluation, Authorization and restriction of Chemicals
ESPR: Eco-design for Sustainable Products Regulation
