The European Commission’s climate and energy legislative package — the so-called “Fit for 55” or “Target 55” package — aims to ensure a smooth transition towards EU-wide climate neutrality. The areas it covers include climate, energy and fuels, transport, buildings, land use, and forestry. A clear and comprehensible political objective. Yet for some reason, we recently discovered that, on the matter of land use and forestry, someone, somewhere, at some point had already agreed on specific carbon sequestration figures? And that someone else, somewhere, at some point, had also agreed on mandatory cabling numbers for EV charging points in car parks? What followed was a captivating debate on finding someone to blame. Officials were summoned before a special parliamentary committee. State broadcasters demanded that the minister declare in Brussels with a straight back that Estonia was not going to do any cabling — and that, going forward, we had no intention of complying with idiotic directives.
In the middle of this commotion, it is worth looking around to see whether there might be another requirement or regulation waiting around the corner — one already agreed with Brussels, already coordinated domestically with business interest groups, but of which no one has heard anything before. It turns out that no great investigative effort is needed, because such requirements genuinely already exist: the requirements for product circularity and for demonstrating circularity through the digital product passport.
In Estonia, there is a great deal of talk about the circular economy, but in reality we have run into a dead end on this topic. It is fortunate that the digital product passport requirement may help to clarify the reasons — we will likely soon be compelled to seek a way out as well. Our problem is that we treat the circular economy as a new way of managing waste. We assume that if we collect rubbish in a slightly more sorted manner and work our way through the waste hierarchy performing recovery operations, we are engaging in the circular economy. In practice, we are not. Recovery operations are certainly important, but the circular economy is an entirely different matter. To be fair, this misreading has not yet prevented €111 million from being invested in the circular economy, and the misconception that has run into a dead end will presumably be cemented undisturbed into the Climate Act as well. Since businesses are already aware of which products and services a market transitioning from a linear to a circular economy demands, however, it is to be hoped that at least the digital product passport requirement will at some point open a discussion on the regulatory changes needed at the legislative level.
Estonia lacks the comprehensive approach needed to activate the circular economy — one that accounts for the entire value chain, from production through to returning raw materials to the market. In countries where circular economy principles are genuinely applied, such as Finland, it is understood that the circular economy is a new economic model whose goal is to create a secondary raw materials market. This is a market in which recovered resources of equivalent quality to primary resources are available. Such a market encompasses product design, innovation, business model transformation, resource efficiency, and broader collaboration between businesses, the public sector, and society. Unlike in Estonia, these are not merely words but a clear strategic direction for how to build a secondary raw materials market and transition from a linear to a circular economy. And unlike the Estonian understanding, a circular raw materials market is not a platform for selling waste or production residues that someone may happen to want to use.
The digital product passport requirement could become a catalyst for change — there is at least reason for hope. At first glance, the digital product passport may seem like a technological novelty that should present no particular challenge for Estonia. If needed, we could quickly build another demonstration platform on top of it — an Estonian one, a unique environmental declarations platform, for instance. But the digital product passport is not a new IT gadget, and unfortunately we are bystanders in its development. Because we have misunderstood the circular economy, we simply lack the conceptual framework needed to implement the digital product passport. It could well happen, therefore, that we dismiss this requirement too as Brussels bureaucracy and set about fighting it. Since it is a requirement arising from the Ecodesign for Sustainable Products Regulation (ESPR) framework, let it be said in advance: fighting it would be a pointless waste of time.
The purpose of the digital product passport is to improve the environmental performance of products by providing all stakeholders — from suppliers to customers — with comprehensive information about the resources used to manufacture a product and about its circularity, as well as disclosing the product’s full environmental impact. All data must be provided; the carbon footprint alone is not sufficient. The first sector in which the digital product passport requirement will be transposed into Estonian law is the manufacturing of construction products. It should be noted, however, that it will expand step by step to other sectors as well. I believe these developments should be embraced as opportunities to learn from EU directives — to consider how to genuinely begin exiting the linear economy and which assumptions need to be revised so that circular economy business models can be applied in Estonia too.
This article was published in Eesti Päevaleht on 9 April 2025: https://epl.delfi.ee/artikkel/120369422/anu-kull-utleme-lollidele-euroopa-liidu-direktiividele-ei-siis-voime-ise-kilplasteks-jaada