The EU’s Ecodesign for Sustainable Products Regulation (ESPR), is setting the stage for Digital Product Passports (DPPs). While they are not yet mandatory for cosmetics, forward-thinking brands are already planning ahead for digital tracking.
As the European Commission describes it, a DPP is a digital container for a product’s lifecycle data. Its purpose is to support sustainability and circularity, and to make legal compliance easier. Improving traceability across supply chains helps people assess product sustainability, supports reuse and recycling. DPPs also streamline the enforcement of rules against non-compliant goods. If a product is sold in the EU it will need a DPP–even if manufactured outside the EU.
Global Supply Chains and Digital Adaptation
As highlighted by the World Economic Forum, China is the birthplace of the global green industrial revolution. China is also the powerhouse of cosmetic OEM/ODM manufacturing and AI-driven beauty-tech, with a domestic beauty market surpassing $70+ billion, the second-largest behind the U.S.. In short, Western beauty brands rely on Chinese manufacturing.
In response to Europe’s strict Digital Product Passport regulations, the state-backed China Academy of Information and Communications Technology (CAICT) built domestic DPP architecture. While the EU may have invented the transparency rules, China is rapidly building the digital ecosystem for its export economy in order to meet Europe’s green targets.
Digital Infrastructure Expansion and Environmental Oversight Challenges
To make this work, the EU is banking on a decentralized digital infrastructure. Digitization is being championed as the ultimate enabler of the Green Deal’s transition to a clean energy grid. It demands immense computing power and power grids requiring millions of industrial backup batteries. In fact, batteries are the first products legally mandated to have a Digital Product Passport (DPP). This “Electrification Action Plan” does, however, create some serious challenges.
Just last week, authorities in Finland had to halt Google’s data center expansion after the tech giant cleared a forest (an estimated 250,000 trees) without completing mandatory environmental impact assessments, driving local wolf populations into residential areas.
If the global digital infrastructure required to enforce compliance cannot itself be kept compliant–as demonstrated by Alphabet, Inc.’s Google, a company valued at $3.9 trillion, this double-standard worsens the crisis of credibility.
As the beauty industry prepares for cosmetic digital passports, which may still be years away, the data infrastructure behind them may seem far removed from clean beauty concerns. Nonetheless, if DPPs are built to trace the supply chains of consumer products, it raises the obvious question: who is monitoring the monitors? Furthermore, for the third-party certifiers and consumers who spent decades building the West’s ethical beauty landscape, the contrast is striking. The EU protects animals from laboratory harm, yet the multi-trillion dollar tech entities integral to the green compliance architecture are harming the environment they are meant to be protecting and preserving.