Chemical Compliance Meets Digital Product Passports
The intersection of REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals) and Digital Product Passports is one of the less discussed but critically important aspects of ESPR compliance. Article 8(2)(e) of the ESPR requires that DPPs include information about substances of concern, including Substances of Very High Concern (SVHCs) as defined under REACH.
This is not new information for manufacturers — REACH Article 33 already requires communication of SVHCs above 0.1% concentration by weight. What is new is that this information must now be structured, machine-readable, and accessible via the Digital Product Passport.
What Data Is Required
For each SVHC present in the product above 0.1% w/w:
- Chemical name and CAS number
- Concentration range
- Location within the product (which component)
- Safe use instructions
- Relevant REACH authorisation or restriction status
For battery passports specifically, the regulation requires disclosure of hazardous substances in the battery and its components, cross-referencing the REACH Candidate List and Annex XIV (Authorisation List).
The SCIP Database Connection
Many manufacturers already report SVHC data to ECHA’s SCIP (Substances of Concern In articles as such or in complex objects/Products) database. The DPP does not replace SCIP reporting but extends it by making the same data accessible to consumers, recyclers, and market surveillance authorities through a standardised digital interface.
Forward-thinking manufacturers are structuring their SCIP submissions in a way that allows direct mapping to DPP data fields — avoiding duplicate data entry.
Practical Implications for Manufacturers
The biggest challenge is not the data itself — most manufacturers know which SVHCs are in their products. The challenge is extracting this information from material safety data sheets (SDS), supplier declarations, and test reports, and structuring it in the machine-readable format required by the DPP.
This is where AI document intelligence becomes valuable. Platforms like Traceable can extract SVHC data from uploaded SDS documents and automatically map it to the correct DPP fields, reducing manual data entry and improving accuracy.
Looking Ahead
The European Commission has signalled that chemical transparency will be a core pillar of the DPP across all product categories. Manufacturers who build robust chemical data management processes now will be well-positioned as DPP requirements expand from batteries to textiles, electronics, and construction products.