Material composition is one of the most data-intensive DPP requirements — and one where many manufacturers initially underestimate the complexity. Here's a systematic guide to what you need to declare and where to get the data.
Hazardous Substance Declarations (REACH)
Under REACH Article 33, any product containing a Substance of Very High Concern (SVHC) above 0.1% by weight (per article) must be disclosed on request. DPP regulations are extending this to mandatory proactive disclosure in the DPP. The SVHC Candidate List (updated by ECHA twice yearly) currently contains 240+ substances. Key categories:
- CMR substances (carcinogenic, mutagenic, reprotoxic)
- PBT/vPvB (persistent, bioaccumulative, toxic)
- Endocrine disruptors
- Specific hazardous categories per sector (flame retardants in electronics, azo dyes in textiles, plasticisers in PVC)
Recycled Content
DPPs must distinguish between:
- Pre-consumer recycled content: Manufacturing waste/offcuts recycled back into production. Counts towards recycled content but at a lower weighting in some methodologies.
- Post-consumer recycled content: Material recovered from products at end-of-life (e.g., recycled aluminium cans). Higher weighting — this is the kind of recycling that has real environmental impact.
The ISO 14021 standard defines methodologies for calculating and verifying recycled content claims. Third-party verification is required under the Battery Regulation for recycled cobalt, lithium, nickel, and lead content.
Where to Get the Data
- Substance declarations from suppliers: Most chemical suppliers provide REACH declarations listing SVHCs in their products. Request these as a condition of purchase.
- SCIP database (ECHA): Suppliers are legally required to notify ECHA of SVHCs in articles they supply — you can look up your supplier's SCIP notifications.
- Test reports: X-ray fluorescence (XRF) testing can identify heavy metals in materials. Third-party testing labs can provide material composition reports.
- Your own bill of materials: Map your BOM against substance databases (ECHA, ChemSec SINList) to flag potential SVHCs.
Critical Raw Materials
The EU Critical Raw Materials Act (CRMA, Regulation (EU) 2024/1252) designates 34 critical raw materials (CRMs) and 17 strategic raw materials. DPPs for electronics, batteries, and renewable energy equipment must report CRM content. This includes: cobalt, lithium, natural graphite, rare earth elements (neodymium, dysprosium), silicon metal, and others.