Substances of concern are where the Digital Product Passport meets a decade of existing EU chemicals law. If your articles contain Substances of Very High Concern from the REACH Candidate List, you already have duties: informing customers down the supply chain and notifying ECHA’s SCIP database. ESPR now makes substance-of-concern tracking a core purpose of the DPP. The overlap is not a burden doubling — it is an opportunity: the same supplier declaration can feed both obligations, if you collect it in a structured way once.
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The ESPR’s circularity logic depends on knowing what is inside a product. Recyclers cannot safely process what they cannot identify; repairers and refurbishers need to know what they are handling; regulators want hazardous substances traceable through the loop. That is why tracking substances of concern is one of the explicit purposes of the Digital Product Passport framework: passports are designed to carry information on substances of concern present in the product, so that the information survives the product’s journey to reuse and recycling.
The exact substance data required for each product group will be set in that group’s delegated act — so the precise field list varies. But the direction is unambiguous: substance transparency is a pillar of the regime, not an optional extra.
Since 2021, under the Waste Framework Directive, EU suppliers of articles — not just chemicals — must notify ECHA’s SCIP database when an article contains a Substance of Very High Concern from the REACH Candidate List above the concentration threshold set in the Waste Framework Directive. The notification identifies the article, the SVHC and where it sits, and instructions for safe use; the database exists precisely so that waste operators and consumers can find this information later.
Two practical pain points are familiar to anyone who has done it: the Candidate List is updated periodically, so a compliant product can drift into scope when a new substance is added; and the data has to come from suppliers who may be several tiers away from the substance in question. Both problems — a moving list and deep supply chains — are exactly the problems DPP substance data has too.
Look at what each regime actually needs from you and the duplication is obvious:
A full material or substance declaration from your supplier answers all of these once. From that single record you can generate the SCIP notification, the customer communication duty under REACH, and the substance section of a Digital Product Passport — plus answers to the customer questionnaires you are already receiving. What makes this fail in practice is format: PDFs and emailed statements that must be re-read by a human for every new output. What makes it work is structure: substance, CAS/EC identity, location, concentration captured as data, tied to the exact product version and supplier evidence.
Practical sequence: start from your bill of materials and identify which components plausibly carry Candidate List substances (electronics, plastics, coatings, textiles with treatments are the usual suspects). Request declarations at component level, in a structured format, with the supporting document attached — not a bare "we comply" letter. Version everything: declarations age as the Candidate List grows, so record the list version a declaration was made against and re-check on updates. Then hold it all in one place from which each regulatory output is generated, rather than rebuilding the dataset per obligation.
This is the model PassPer is built on: our AI extracts substance and material data from the documents your suppliers already produce — declarations, test reports, certificates — with human review, and holds it as structured, evidence-linked records ready for passport publication. Run the free readiness check to see how much of your substance data is already sitting in documents you have.
Take the 2-minute readiness check, watch the 10-minute interactive walkthrough, or download the full 2026 compliance guide. No account needed.