Appendix B

Universal Product Passport Standards (UPPS)

Version 1.0

Effective: May 2026

Sector Guidance

Industry-specific guidance for implementing UPPS standards.

This appendix provides sector-specific guidance to help organizations apply UPPS standards effectively within their industry context. Sector guidance addresses unique challenges, regulatory requirements, and best practices for each industry.

1. Battery Products (UPPS 601)

Sector Overview

Battery products are subject to the EU Battery Regulation and other global regulations requiring comprehensive product passports. Key challenges include complex material composition, critical raw material traceability, carbon footprint calculation, and end-of-life management.

Key Regulatory Requirements

  • •EU Battery Regulation (2023/1542): EU Battery Regulation (2023/1542): Mandates battery passports for industrial and EV batteries above 2 kWh, with specific disclosure requirements
  • •Carbon Footprint: Carbon Footprint: Required for batteries above 2 kWh from 2027, with phase-in for smaller batteries
  • •Recycled Content: Recycled Content: Minimum recycled content requirements for cobalt, lead, lithium, and nickel
  • •Due Diligence: Due Diligence: Supply chain due diligence for raw materials per EU Conflict Minerals Regulation

Unique Data Quality Challenges

  • •Multi-tier traceability: Multi-tier traceability: Battery value chain spans mining, refining, cathode/anode production, cell manufacturing, and pack assembly
  • •Material complexity: Material complexity: Complex cathode chemistries (NMC, LFP, NCA) with varying material compositions
  • •Global supply chains: Global supply chains: Raw materials sourced from diverse geographic regions with varying data availability
  • •Carbon footprint complexity: Carbon footprint complexity: Energy-intensive manufacturing processes with varying grid electricity emissions

Recommended Implementation Approach

1

Start with EU Battery Regulation Alignment

Map UPPS 601 requirements to EU Battery Regulation passport requirements to ensure compliance

2

Establish Material Traceability

Implement batch-level or material-level traceability for critical raw materials (cobalt, lithium, nickel)

3

Calculate Carbon Footprint

Follow EU Product Environmental Footprint (PEF) methodology for battery carbon footprint calculation

4

Engage Tier 1 Suppliers

Require suppliers to provide material composition, origin, and environmental data through standardized questionnaires

5

Plan for Third-Party Verification

EU Battery Regulation requires third-party verification for battery passport data

Sector-Specific Data Sources

Environmental Data

  • • Battery Passport PEF database
  • • Ecoinvent battery datasets
  • • GaBi battery LCA databases
  • • IEA electricity emission factors

Material Data

  • • Responsible Minerals Initiative (RMI)
  • • Cobalt Institute data
  • • Lithium industry associations
  • • Supplier material certificates

2. Textile Products (UPPS 602)

Sector Overview

Textile products face increasing regulatory pressure on transparency, chemical safety, and environmental impacts. Key challenges include fiber composition verification, chemical usage tracking, water consumption, and social compliance across geographically dispersed supply chains.

Key Regulatory Requirements

  • •EU Ecodesign for Sustainable Products Regulation (ESPR): EU Ecodesign for Sustainable Products Regulation (ESPR): Digital Product Passport requirements for textiles
  • •EU Textile Regulation: EU Textile Regulation: Fiber composition labeling and durability requirements
  • •REACH: REACH: Restriction of hazardous substances in textiles
  • •EU Strategy for Sustainable and Circular Textiles: EU Strategy for Sustainable and Circular Textiles: Extended producer responsibility and eco-design requirements

Unique Data Quality Challenges

  • •Complex fiber blends: Complex fiber blends: Multi-fiber compositions requiring precise material attribution
  • •Chemical complexity: Chemical complexity: Hundreds of chemicals used in dyeing, finishing, and treatment processes
  • •Global supply chains: Global supply chains: Cotton from multiple countries, processing in different regions, assembly in yet another
  • •Social compliance: Social compliance: Labor rights and working conditions across diverse regulatory environments

Recommended Implementation Approach

1

Verify Fiber Composition

Conduct laboratory testing to verify fiber composition claims, especially for blended materials

2

Map Chemical Usage

Implement chemical inventory tracking system compliant with REACH and ZDHC

3

Track Water and Energy

Collect water consumption and energy use data from key processing facilities

4

Social Compliance Audits

Conduct regular social audits using recognized standards (SA8000, BSCI, Sedex)

5

Durability Testing

Conduct standardized durability testing (pilling, colorfastness, tensile strength)

Sector-Specific Data Sources

Environmental Data

  • • Higg Index FEM
  • • Textile Exchange data
  • • Ecoinvent textile datasets
  • • ZDHC chemical database

Social Data

  • • Better Work program data
  • • Fair Wear Foundation
  • • Sedex member data
  • • Social audit reports

3. Electronics Products (UPPS 603)

Sector Overview

Electronics products are subject to extensive regulations on hazardous substances, energy efficiency, and e-waste management. Key challenges include complex bill of materials, critical raw materials, repairability requirements, and software support obligations.

Key Regulatory Requirements

  • •EU Right to Repair Directive: EU Right to Repair Directive: Repairability requirements and spare parts availability
  • •RoHS Directive: RoHS Directive: Restriction of hazardous substances in electrical and electronic equipment
  • •WEEE Directive: WEEE Directive: Waste electrical and electronic equipment management and recycling targets
  • •EU Conflict Minerals Regulation: EU Conflict Minerals Regulation: Due diligence for tin, tantalum, tungsten, and gold (3TG)

Unique Data Quality Challenges

  • •Complex BOM: Complex BOM: Hundreds to thousands of components per product with varying material compositions
  • •Critical raw materials: Critical raw materials: 3TG minerals, rare earth elements, and other materials with supply chain risks
  • •Repairability assessment: Repairability assessment: Quantifying repairability based on disassembly ease, spare parts availability, and documentation
  • •Software support: Software support: Tracking software update commitments and security patch availability

Recommended Implementation Approach

1

Develop Detailed BOM

Create comprehensive bill of materials with material composition for all components

2

Conduct Conflict Minerals Due Diligence

Implement RMI or equivalent due diligence process for 3TG minerals

3

Assess Repairability

Calculate repairability index following EU methodology (disassembly, spare parts, documentation)

4

Define Software Support Commitments

Document software update periods, security patch commitments, and end-of-support dates

5

Verify RoHS Compliance

Ensure compliance with RoHS restricted substances through testing and supplier declarations

Sector-Specific Data Sources

Environmental Data

  • • Ecoinvent electronics datasets
  • • GaBi electronics LCA data
  • • ENERGY STAR data
  • • EPEAT registry

Material Data

  • • Responsible Minerals Initiative (RMI)
  • • Conflict-free smelter program
  • • Material declarations (IEC 62474)
  • • Supplier BOM data

4. Emerging Sector Guidance

UPPS sector guidance is under development for the following industries. Organizations in these sectors should apply general UPPS standards while anticipating sector-specific guidance.

Automotive

Vehicles and automotive components including EV batteries, tires, and interior materials. Focus on lifecycle emissions, material composition, and end-of-life vehicle recycling.

Status: Planned for future development

Construction Materials

Building materials including cement, steel, glass, insulation, and wood products. Focus on embodied carbon, material sourcing, and circular construction practices.

Status: Planned for future development

Food & Beverage

Food products and beverages including ingredients, packaging, and agricultural sourcing. Focus on nutritional information, origin labeling, and environmental footprint.

Status: Planned for future development

Chemicals

Industrial chemicals and chemical products. Focus on chemical safety, REACH compliance, hazardous substance disclosure, and environmental impact.

Status: Planned for future development

5. Cross-Sector Considerations

SME Considerations

Small and medium-sized enterprises may face challenges implementing UPPS due to limited resources and capacity. SMEs should:

  • •Start with UPPS 101 (General Product Disclosures) as the minimum baseline
  • •Use industry averages and secondary data where primary data is unavailable
  • •Leverage sector associations and industry initiatives for data and support
  • •Implement phased approach, prioritizing high-impact disclosures first

Multi-Sector Organizations

Organizations operating across multiple sectors should:

  • •Apply sector-specific guidance for each product category
  • •Maintain consistent data quality and assurance processes across sectors
  • •Develop centralized data governance while allowing sector-specific flexibility
  • •Coordinate assurance engagements across sectors to avoid duplication

Regulatory Divergence

Different jurisdictions may have varying regulatory requirements for product disclosures. Organizations should:

  • •Identify all applicable regulatory requirements for each market
  • •Use UPPS Regulatory Mapping Framework to align disclosures with multiple regulations
  • •Implement the most stringent requirement where regulations diverge
  • •Maintain flexibility to adapt to evolving regulatory landscapes
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