Understanding DPP Laws, Regulations, and Business Requirements

Two laws governing the DPPs

There are currently two key laws that mandate some form of DPP as a significant part of their requirements, one in France and the EU’s ESPR.

France’s version of DPP law

The French Anti-Waste Law, or loi anti-gaspillage pour une économie circulaire (Loi AGEC), is a comprehensive law aiming to reduce waste and apply specific requirements to products in France. The law mandates that environmental details of specified products placed on the French market must be disclosed to consumers.

This information is required in French and should be electronically accessible at the time of purchase through a digital product sheet on a website. A practical way to meet this requirement is through product-specific web pages or DPP, accessible through a link or QR code at the point of sale, whether online or in-store.

Many retailers in France and those who sell into France are already implementing DPP across entire portfolios of products to ensure they remain compliant considering the now mandatory requirements.⁸

DPP’s synergistic relationship with The Critical Raw Materials Act

Another key piece of legislation enacted by the EU and part of the EGD initiative is the Critical Materials Act (CRMA) regulation adopted May 23, 2024. Designed to secure a sustainable and reliable supply of critical raw materials for European industries, the new act’s goals are to strengthen the production, processing, and recycling of strategic raw materials with the EU.⁹

The CRMA aims to bolster the EU’s strategic autonomy by reducing reliance on external suppliers for CRMs. Essential to produce batteries, renewable energy technologies, and various high-tech applications, these materials include lithium, cobalt, and nickel.

To meet these objectives, the CRMA has set targets for strategic raw materials for 2030 that include:

• 10% of the EU’s annual consumption for extraction to be sourced domestically.
• 40% of the EU’s annual consumption for processing to occur within the EU.
• 25% of the EU’s annual consumption to come from recycling.

Additionally, the Act mandates that no more than 65% of any strategic raw material should be sourced from a single third country, consequently reducing the risk of supply chain disruptions.¹⁰

The CRMA is expected to work in parallel with the passport to provide detailed information about the origin, composition, and lifecycle of critical raw materials within a product. This will enable better tracking and compliance with the Act’s requirements for responsible sourcing and recycling of these materials.

DPP’s synergistic relationship with The Critical Raw Materials Act

Another key piece of legislation enacted by the EU and part of the EGD initiative is the Critical Materials Act (CRMA) regulation adopted May 23, 2024. Designed to secure a sustainable and reliable supply of critical raw materials for European industries, the new act’s goals are to strengthen the production, processing, and recycling of strategic raw materials with the EU.⁹

The CRMA aims to bolster the EU’s strategic autonomy by reducing reliance on external suppliers for CRMs. Essential to produce batteries, renewable energy technologies, and various high-tech applications, these materials include lithium, cobalt, and nickel.

To meet these objectives, the CRMA has set targets for strategic raw materials for 2030 that include:

• 10% of the EU’s annual consumption for extraction to be sourced domestically.
• 40% of the EU’s annual consumption for processing to occur within the EU.
• 25% of the EU’s annual consumption to come from recycling.

Additionally, the Act mandates that no more than 65% of any strategic raw material should be sourced from a single third country, consequently reducing the risk of supply chain disruptions.¹⁰

The CRMA is expected to work in parallel with the passport to provide detailed information about the origin, composition, and lifecycle of critical raw materials within a product. This will enable better tracking and compliance with the Act’s requirements for responsible sourcing and recycling of these materials.

Key points about this synergy:

• Boosting domestic production: The CRMA aims to incentivize the development of mining, processing, and recycling facilities within the EU to increase domestic production capacity.
• Circular economy potential: DPPs facilitate the identification and recovery of valuable critical materials at the end-of-life stage (EOL), consequently promoting recycling and reuse practices. This initiative aligns with the broader objectives of the Critical Materials Act.
• Focus on critical raw materials: The act specifically targets materials considered crucial for the EU’s economy and technological advancement, including those used in renewable energy and digital technologies.
• Supply chain diversification: A major goal is to reduce dependence on single sources of critical raw materials by diversifying import origins.
• Sustainability emphasis: The legislation promotes sustainable practices in the extraction and recycling of critical raw materials.
• Traceability: DPPs can store information on the source of critical raw materials, allowing authorities to identify potential issues in the supply chain and ensure compliance with the CRMA.