In this post, we explore how digital product passports informed by the Web Sustainability Guidelines (WSGs) could be key to addressing some of the web’s biggest challenges. 

The European Commission recently passed the Ecodesign for Sustainable Products Regulation (ESPR). This legislation aims to unlock circularity and make more sustainable products the norm across the European Union (EU) market.

While the regulation is currently specific to several physical product categories in the EU, it has sweeping implications across industries and geographies. Manufacturers, distributors, retailers, and importers around the world who sell products in the EU will need to abide by its guidelines, especially as more and more product groups fall under the law’s purview over time. 

ESPR Meets Digital Products and Services

Also, ESPR could have potential future ramifications for digital products and services as well. The legislation includes something called a Digital Product Passport (DPP), which aims to:

1. Collect product information across a product’s entire life cycle.
2. Store that data in an open digital format.
3. Provide easy access to this data for anyone who wants it.

ESPR currently focuses on physical products primarily in the textiles and electronics industries. However, the plan is to eventually expand the product category list to include everything from furniture and detergents to toys and tires. Might this approach work for web-based products too?

With this in mind, the concept of a product passport could improve many of the environmental, social, and economic issues that currently plague the web. In other words, if you own a website or manage a digital product, this could eventually apply to you. Let’s explore how.

What is a Digital Product Passport?

Moving quickly and unlocking DPP-enabled transparency early can help decouple economic growth from resource extraction, waste streams and carbon emissions, thereby significantly affecting the wellbeing of the planet and humanity.

— The EU Digital Product Passport Shapes the Future of Value Chains, World Business Council for Sustainable Development

Currently, there is a significant lack of reliable, publicly available data on product journeys. This includes sustainability data as well as information on regulatory compliance, safety, use instruction, hazardous materials, and so on. This causes many problems, including greenwashing and not addressing the climate emergency and global sustainable development goals in meaningful ways. 

A digital product passport is a record that contains data across a product’s entire value chain, from initial designs to end of life. Similar to traditional passports, they reveal key information about a product along its life cycle journey. What’s more, digital product passports enhance transparency by offering better product data that can help stakeholders—such as consumers and investors—make more informed decisions. 

Each product that employs one of these digital passports has a unique identity linked to information on that specific product. Criteria includes (but is not limited to):

• Unique product identifiers and global trade IDs
• Regulatory compliance documentation
• User manuals, instructions, and safety information
• Rights in materials and intellectual property
• Third-party supplier data
• Hazardous substance data
• Repairability, recyclability, and end-of-life guidance

The idea is that consumers, investors, or other product stakeholders could easily access decentralized information—via a QR code attached to a product, for instance—to inform purchasing decisions, funding, identify strategic vendor or supplier partnerships, or any number of other opportunities.

Features & Benefits of Digital Product Passports

Digital product passports offer several important features:

1. Transparency: They help companies and customers build trust through increased public transparency in how to design, build, distribute, and recycle or dispose of products.
2. Traceability: Digital traceability of materials and resources can open more demand for sustainable products and help companies better understand how to prioritize sustainable design and circular economy principles in their own product development cycles.
3. Regulatory: By including digital product passports in ESPR legislation, the EU also ensures wide adoption, which is key to advancing a circular economy. This will no doubt inspire other jurisdictions to follow suit. 

Benefits of this include:

• Improved relationships between companies and their stakeholders
• Risk reduction across the value chain
• Better technology infrastructure to manage product data
• Improved supply chain management
• Increased regulatory compliance
• Lower employee attrition rates and reduced instances of worker exploitation
• A more regenerative economy that helps us stay within global ecological boundaries

Potential Risks and Challenges

Digital product passports face some real challenges and potential risks as well:

1. Industry lobbies: Because of additional infrastructure and resources required to effectively manage digital product passports over time, it seems inevitable that some industry lobbies will fight these efforts.
2. Standards identification: To date, many circularity tools offer proprietary tech solutions when we need open, non-proprietary standards to advance the circular economy.
3. Interoperability: Iin order to realize this long-term vision, organizations of all sizes across industries, countries, and technologies should experience reduced barrier to entry through interoperability for digital product passports.
4. Quality assurance: Data quality and security risks are likely unless effective governance, follow-through, and maintenance strategies occur.

Perhaps most importantly, timing for these efforts is urgent. We can’t water down this legislation or hold it up in endless negotiations. We need quick and decisive action.

Digital Product Passport Rebound Effects

Importantly, digital product passports will require product owners to create and manage far more data about their product portfolios than many currently do. With millions and millions of products on the global market, there are significant sustainability ramifications to this.

Our thirst for all things data-related already drives major social and environmental challenges around the world. This is especially true with the fast rise of artificial intelligence, though social media, cloud computing, blockchain, and other emerging technologies, like quantum computing, contribute to these challenges as well.

In order to balance the good that digital product passports offer with the potential increase in resources needed to manage them, effective digital governance in general and data governance specifically will be critical sustainability strategies for long-term success. This will help teams build capacity, reduce risk, and create more resilient organizations while also effectively managing the sustainability implications associated with implementation. 

This brings up two concerns:

1. Organizations aren’t historically very good at managing digital products over time, let alone prioritizing digital sustainability across their product lines.
2. Are required trade-offs worth potentially extensive rebound effects? 

Regardless, with an estimated 334 million companies around the world, this is a monumental challenge. 

Given all this, how might we apply digital product passport principles to web-based products and services in the name of improving sustainability? 

Digital Product Passports for the Web

Sustainable web design practices and digital life cycle assessments can address the web’s significant sustainability challenges in meaningful ways. However, few organizations to date embrace these practices. 

The Web Sustainability Guidelines (WSGs)—created by the World Wide Web Consortium’s (W3C) Sustainable Web Design community group–can serve as a driver for potential web-based product passports. 

This is because:

• They provide guidance across the entire life cycle of a digital product or service.
• Each guideline includes environmental, social, and economic success criteria along with recommendations for how to measure progress.
• The guidelines provide signposts to related interdependent disciplines like accessibility and the W3C’s Ethical Web Principles.
• Organizational product teams can find meaningful recommendations regardless of discipline since they include guidance on a variety of roles (UX designers, product managers, web developers, etc.). See the full list of categories on the Sustainable Web Design site.

Legislation-backed digital product passports driven by the Web Sustainability Guidelines could be a solution for solving some of the web’s biggest challenges.  

Potential Benefits of Web-Based Product Passports

The benefits of WSG product passports for websites and other digital products might include:

• Transparency: Increased transparency in how we create and manage digital products and services could reduce churn and improve relationships between technology providers and their customers. 
• Security: Similarly, improved security reduces web hacks and data breaches. Understanding this helps customers make more informed decisions. 
• Data privacy: Also, understanding the practices organizations employ to protect customer data can build trust with customers. 
• Supply chain: Improved digital supply chain management helps marketers and other technology-adjacent stakeholders better understand the potential implications of their partner choices.
• Emissions reduction: Finally, improving transparency around a product’s digital carbon footprint will help organizations reduce emissions, especially for Scope 3.

Challenges to Web-Based Product Passports

Unfortunately, web-based digital product passports will also face several big hurdles. We’re already seeing adoption challenges with the Web Sustainability Guidelines. Tech has generally been slow to implement meaningful sustainability practices across the sector. Similarly, legislators don’t often include digital products and services in regulatory sustainability guidance. Thankfully, both these things are changing quickly.

Other challenges and risks associated with web-based passports are similar to those for physical products:

• Industry lobbies: Tech lobbyists could potentially use their significant influence to water down, delay, or otherwise block potential passport regulations. 
• Costs: Product passports could possibly increase training and development costs associated with digital products and services. This might disincentivize organizations from embracing them.
• Awareness: There is still a large lack of awareness and education about many social and environmental issues associated with tech. 
• Interoperability: Passport solutions must be interoperable across devices and platforms to achieve widespread adoption. Delayed or watered down standards could undermine this.

Eleven Features of Web-Based Digital Product Passports

Here are eleven potential feature ideas informed by the Web Sustainability Guidelines that could drive success for web-based digital product passports.

1. URL and Domain Ownership

Web-based product passports should provide up-to-date contact information for the person and/or organization that owns a product or service and is responsible for product sustainability.

WSG Alignment: 5.2, Assign a Sustainability Representative

2. Life Cycle History

They should also include data on the product’s life cycle history, including:

• Year launched
• Who designed and built the product
• Who maintains it
• History of updates, including potentially outdated software and progress over time against specific sustainability goals

WSG Alignment: 2.25, Conduct Regular Audits, Regression, and Non-Regression Tests; 5.12, Implement Continuous Improvement Procedures; 5.13, Document Future Updates and Evolutions; 5.15, Determine the Functional Unit; 5.22, Promote and Implement Responsible Emerging Technology Practices

3. Security Measures for Data Breaches

Similarly, a passport should make it easy to understand the security measures an organization takes to protect stakeholder data through use of its products. 

• Security: Does the product employ a content security policy, firewall software, and other security measures?
• Maintenance: Does it regularly maintain software updates and keep a product’s codebase up to date?
• Transparency: Is the organization transparent about when breaches occur and what is at risk?

WSG Alignment: 2.2, Assess and Research Visitor Needs; 2.25, Conduct Regular Audits, Regression, and Non-Regression Tests; 3.16, Ensure Your Scripts are Secure; 5.13, Document Future Updates and Evolutions; 5.20, Promote Responsible Data Practices; 5.25, Plan for a Digital Product or Service’s Care and End-of-Life

4. Regulatory Compliance 

Technology legislation changes regularly. A useful product passport will outline: 

• Which laws the product must comply with (security, accessibility, data privacy, intellectual property, and so on)
• Date and results of the last audit
• Specific measures to improve compliance over time
• Pending legislation that could impact website policies

WSG Alignment: 3.8, Use HTML Elements Correctly; 3.16, Ensure Your Scripts are Secure; 3.20, Avoid Using Deprecated or Proprietary Code; 5.9, Support Mandatory Disclosures and Reporting; 5.20, Promote Responsible Data Practices

5. Website Policies 

An impactful product passport will collect (and potentially summarize) an organization’s policy pages and official statements in a single location. Examples include:

• Code of ethics
• Privacy policies
• Supplier policies
• Open source policies
• DEI statements
• Accessibility statements
• Sustainability statements
• And so on …

WSG Alignment: 5.16, Create a Supplier Standards of Practice; 5.19, Use Justice, Equity, Diversity, Inclusion (JEDI) Practices; 5.21, Align Technical Requirements with Sustainability Goals; 5.23, Include Responsible Financial Policies; 5.24, Include Organizational Philanthropy Policies; 5.26, Include E-Waste, Right-to-Repair, and Recycling Policies; 5.28, Use Open Source Tools

6. Organizational Commitments

Similarly, shared economic prosperity means extending these principles to the policies and practices of the organization itself, not just the products or services it builds. We should capture (and, again, potentially summarize) this information in a central location to help potential customers, suppliers, or partners make more educated decisions. Examples include:

• Third-party certifications, like B Corp and others
• Online ratings, such as those from Charity Navigator, Net Promoter, and others
• Product specifications (non-regulatory related)
• Impact Business Models (IBMs)

WSG Alignment: 5.6, Verify Your Efforts Using Established Third-Party Business Certifications; 5.10, Create One or More Impact Business Models; 5.5, Estimate a Product or Service’s Environmental Impact

7. Third-Party Suppliers

Third-party services work behind the scenes of a digital product or service. They are often invisible to front-end customers. This could put both product performance and stakeholder data at risk. A successful web-based digital product passport will reveal third party suppliers to help customers make more informed decisions.

• Agency data: Who designed and built the site? Who maintains it?
• Hosting: Where are the product and its third-party services hosted? Are they credible resources with clear sustainability or Net Zero commitments? 
• Software: Who creates and maintains website plugins, scripts, and third-party services like newsletter subscriptions and CRM systems? Have these third parties made credible sustainability commitments? Do they present potential security risks?
• Advertising: Are third-party cookies, ad trackers, and so on managed by reputable companies? Have they made credible social and environmental commitments? 

WSG Alignment: 3.7, Rigorously Assess Third-Party Services; 3.17, Manage Dependencies Appropriately; 5.16, Create a Supplier Standards of Practice

8. Digital Carbon Ratings

Similar to EnergyStar and related energy efficiency ratings on appliances and electronic devices, digital carbon ratings aim to shed light on similar metrics for digital products and services. Including this information in digital product passports helps people better understand an organization’s commitment to addressing climate change.

WSG Alignment: 5.9, Support Mandatory Disclosures and Reporting

9. Energy Data

Energy data transparency is critical to meaningfully address runaway tech sector emissions. Unfortunately, major energy data gaps exist within tech systems. This undermines an organization’s ability to report the full-scale of its emissions profile, especially Scope 3. We need publicly available disclosures to fill these gaps. Providing this data in a product passport could help. 

• Hosting: Does the product use renewable energy-powered hosting? What is the carbon intensity in a product or service’s hosting region? 
• Third-party services: Similarly, does a product or service power its third-party services, scripts, or frameworks with renewable energy?
• Measurement: How does the product estimate emissions, what’s the reduction strategy, and which methodology is used to estimate them?

WSG Alignment: 4.1, Choose a Sustainable Hosting Provider; 5.1, Have an Ethical and Sustainability Product Strategy; 5.5, Estimate a Product or Service’s Environmental Impact; 5.9, Support Mandatory Disclosures and Reporting

10. Data Privacy Practices

People must have the right to opt out of companies tracking their interactions across the internet. They must also have the option to remove their personal data from any platform upon request. Including this information in a product passport can help a customer make more educated decisions about which products or services they choose to support. 

• Data collecting: Does the product employ data privacy best practices, like informed consent and opt-in vs. opt-out?
• Data tracking: Which providers does the product share data with? Does the product company sell customer data to others? 
• Spam rating: How often are product communications marked as spam by users?
• Right-to-be-forgotten: How does the organization prove it respects a person’s right to remove personal data completely from marketing lists or company records?

WSG Alignment: 2.2, Assess and Research Visitor Needs; 4.12, Store Data According to Visitor Needs; 5.20, Promote Responsible Data Practices; 5.25, Plan for a Digital Product or Service’s Care and End-of-Life

11. End-of-Life

Finally, people should know what happens to their data when a digital product or service reaches end-of-life. This can mean anything from ownership transfer to an unexpected disaster. Clear policies on these topics could be part of a digital product passport.

• Transitioning data ownership: What, if anything, should customers do in the event of a buyout or ownership transition?
• Data disposal: How does the product retire outdated or otherwise obsolete data?

WSG Alignment: 5.25, Plan for a Digital Product or Service’s Care and End-of-Life; 5.26, Include E-Waste, Right-to-Repair, and Recycling Policies; 5.29, Create a Business Continuity and Disaster Recovery Plan

This list just scratches the surface of what we could potentially include in web-based product passports.

I Manage a Website—What Does This Really Mean to Me?

There is currently no comprehensive legislation that governs social or environmental issues related to digital products and services. Even if a proof-of-concept for web-based product passports comes out next week, the timeline for drafting new ESPR product groups extends into the 2030s, well beyond the expected life cycle (about two years) of today’s typical website. To date, we have seen no mention of software products on the roadmap.

In other words, if you manage a website today, you don’t have to worry about ESPR-related risks anytime soon. However, consider the existing risks for people who own and manage websites:

• Accessibility lawsuits are on a seemingly continuous rise.
• Similarly, data privacy legislation is evolving quickly along with increasing lawsuits. 
• Plus, the average global cost of website hacks and data breaches is about $4.88 million (USD). 

Given this, your organization should consider prioritizing recommendations in this post. If ESPR is successful, web-based product passports could prove to be an attractive option for legislators wanting to address a rapidly rising number of legal issues associated with web-based products and services (though this post shouldn’t be construed as legal advice. If you need legal help, please consult a lawyer).

Advancing DPPs: Actions to Consider

According to policymakers, around 80 percent of a product’s environmental impact is determined by how it is designed. The legislation includes criteria centered on improving product durability, reducing energy consumption, increasing recycled content, facilitating remanufacture and recycling, and increasing the availability of information on just how sustainable a product might be.

— Tom Idle, Will New Ecodesign Regulation Make Sustainable Products the Norm for EU Consumers?, Sustainable Brands

Unfortunately, widespread adoption of circular economy principles has progressed slowly, especially in the business sector. Regulations like ESPR can help to accelerate this transition.

Plus, given ESPR’s potential to change standards of practice across product sector industries, regulatory guidance in other jurisdictions outside the EU will hopefully follow. Legislation like this can help us collectively make the progress necessary to ensure a more sustainable and livable future. 

Unfortunately, ESPR doesn’t yet include digital products and services. However, there are many great groups working hard to improve the practice and delivery of digital products and services via the Web, including the Green Web Foundation, the Green Software Foundation, the International Organization for Standardization (ISO), and our own group under the W3C banner. 

While product passports for digital products and services are still an early stage concept, they show promise. It is definitely something we’re looking into for our web sustainability product, Ecograder.

Want to help drive this and related issues forward? Consider these opportunities:

• Contribute to WSGs: Join the ‘Sustyweb’ group to begin contributing to the Web Sustainability Guidelines.  
• Newsletter signups: Register for updates at any of the organizations listed above.
• Collaboration communities: Join W3C’s Slack community or ClimateAction.Tech to start collaborating today with like-minded people who are passionate about improving the sustainability of tech.

As always, if you have questions, feel free to contact us. Thanks for reading.