Material Composition Declarations in DPPs

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What Are Material Composition Declarations?

Material composition declarations specify the materials and substances that make up a product, including their types, quantities, and any relevant characteristics. Under the ESPR, this information must be included in Digital Product Passports to support recycling, material recovery, and informed consumer choices.

These declarations go beyond simple material lists, they must provide sufficient detail for recyclers to identify and separate materials, for regulators to verify compliance with substance restrictions, and for consumers to understand what they are purchasing.

Required Information

ESPR material composition declarations typically include:

• Material types and grades (e.g., specific polymer types, metal alloys)
• Weight or percentage of each material in the finished product
• Recycled content percentage for each material
• Substances of concern and their concentrations
• Critical raw materials present in the product
• Material origin and supply chain information where required

The level of detail required varies by product category, as specified in the relevant ESPR delegated acts.

Data Collection Challenges

Gathering accurate material composition data can be challenging, particularly for complex products with multiple tiers of suppliers. Sub-assemblies and components may contain materials that the final assembler has limited visibility into.

Establishing data-sharing agreements with suppliers and requiring material declarations as part of procurement processes are essential steps for building comprehensive composition data.

Structuring Material Data

Organise material data hierarchically, reflecting the product's bill of materials structure. This approach makes it easier to maintain accuracy when components change and provides the granularity needed for different stakeholders.

MyProductPassport supports structured material composition data entry with fields aligned to ESPR requirements, making it straightforward to build and maintain accurate declarations.