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The chemical and pharmaceutical industry is fundamental to modern society. With an immense variety of products, from vital medicines and foods, the construction of buildings, to transport and leisure, the industry truly does have an impact on virtually every aspect of our daily lives.
Read moreThe UK must ensure Digital Product Records support greater circularity without creating unnecessary costs and complexity for chemical and pharmaceutical businesses. A separate UK system could duplicate EU requirements and create additional barriers for companies trading across Great Britain, Northern Ireland and the EU. Any future framework should be interoperable with existing systems, proportionate to the information required and introduced gradually, with appropriate protection for commercially sensitive information.
Digital Product Records (DPRs) will play an increasingly important role in how product information is created, shared and used across global supply chains. They can give businesses, regulators and customers more reliable access to the information they need, supporting compliance, product stewardship and circularity.
For the UK chemical and pharmaceutical sectors, the opportunity is significant. However, it will only be realised through a framework that reflects the complexity of international supply chains and avoids creating parallel systems, duplicated data requests and unnecessary costs. The UK should pursue an interoperable and proportionate approach that supports competitiveness while improving the quality and availability of product information.
A practical opportunity for UK industry
DPRs can provide a consistent and accessible source of product information for businesses, regulators, customers and, where relevant, end-of-life operators. For the chemical and pharmaceutical sectors, this could improve access to information on product composition, regulatory status, environmental performance, supply chains and appropriate end-of-life management.
Better information sharing could reduce the need for businesses to repeatedly collect and validate the same data from suppliers and customers. It could also support product stewardship and more informed decisions on reuse, recycling, resource efficiency and circularity.
The UK Government is exploring how DPRs could streamline the provision of product information, improve transparency and support the wider digitalisation of compliance processes through a Call for Evidence on Digital Product Records.
The UK must avoid divergence
Realising the benefits of DPRs will depend on avoiding unnecessary divergence. The EU Digital Product Passport (DPP) framework is developing under the Ecodesign for Sustainable Products Regulation and will apply to relevant products placed on the EU and Northern Ireland markets, including products imported from Great Britain.
Alignment is therefore essential. Chemical and pharmaceutical businesses operate complex international value chains and frequently place products on several markets. Different rules, data carriers or technical systems in Great Britain, Northern Ireland and the EU would create duplication, increase administrative costs and risk disrupting trade.
Any GB framework should align, wherever practical, with EU and international developments. It should use open, interoperable and machine-readable standards, enabling information to move across systems without vendor lock-in. This is consistent with the EU framework, which requires DPP data to use open and interoperable formats.
Data requirements must be proportionate
DPRs should be a tool for sharing product information, rather than a mechanism for imposing prescriptive sustainability or resource-efficiency requirements.
Information requirements should be specific to the product concerned and limited to data that is relevant, justified and practical to provide. A one-size-fits-all approach would not reflect the diversity of chemical and pharmaceutical products, supply chains or data availability.
Businesses often hold substantial information about their own products and operations. However, collecting complete, reliable and current information from multiple suppliers can be challenging. Data may not exist, may be commercially confidential, or may be held in incompatible formats. Generating, validating and maintaining new data can come at significant cost, requiring specialist expertise and sustained engagement across the value chain.
Government should therefore introduce DPR requirements gradually, beginning with the most essential data. The EU anticipates a minimum transition period of 18 months following the adoption of product-specific delegated acts. For complex global supply chains, this should be treated as a minimum, rather than an assumption that implementation will be complete.
Assurance and confidentiality need careful design
Data must be accurate and trustworthy, but assurance requirements should reflect risk. Blanket third-party certification of all DPR data would create disproportionate costs, particularly where information is updated frequently or received from multiple supply-chain partners.
Government should support the use of harmonised, science-based methodologies and allow recognised third-party databases where primary data is unavailable. This would improve data availability while maintaining a credible basis for comparison.
DPR systems must also protect commercially sensitive and proprietary information. Different users will require different levels of access. Businesses should be able to share the information needed for compliance, stewardship and circularity without compromising confidential formulations, commercial relationships or intellectual property.
CIA calls on Government to
A well-designed DPR framework could support better information sharing, stronger product stewardship and more efficient compliance. However, its value will be undermined if it creates fragmented systems, duplicative requests or disproportionate requirements.
The UK should pursue a framework that is streamlined, practical and internationally interoperable, helping businesses meet future product-information needs while maintaining competitiveness and supporting sustainable growth.
Ricardo, with the support of the Chemical Industries Association (CIA), has published a second instalment in their series exploring the environmental impact of chemical products, to help chemical organisations advance their sustainability journey.
