Too Dirty to Enter: On Passporting Traceability

By: Urška Škerl in Featured Articles
Central topics: Supply Chain LandscapesWorld-EcologyExtraction

In December this year, the European Union’s Deforestation Regulation will start to apply to medium and large operators and traders. For micro and small enterprises, the same rules will apply next year. This means that if a commodity, such as cattle, cocoa, coffee, palm oil, soya, rubber, or wood, and products derived from those commodities, contributed to deforestation or forest degradation in the EU and globally, it will not be able to enter the EU market or be exported. This regulation is one of the steps towards the reduction of greenhouse gas emissions and biodiversity loss. The EU is the second-largest importer of tropical deforestation after China, followed by the US. The traders will have to prove that the product entering the market didn’t cause deforestation after 2020. Sounds nice, but there is a catch.

Deforestation is defined as the conversion of a forest, wetland, savanna, or other ecologically valuable area, based on national law, into land for agricultural use. A forest, under this regulation, is any area with woody vegetation covering more than 10 percent of the canopy, with tree species expected to reach at least 5 metres in height. However, deforestation and land degradation could shift to areas and ecosystems not covered by the EUDR. For composite products containing more than one listed commodity, proof is required only for the main ingredient. For example, the regulation doesn’t consider sugar or milk as the main ingredient in a chocolate bar. This opens the question: will producers reduce the percentage of palm oil or other regulated ingredients to avoid scrutiny? The regulation also does not apply to the use of wood for urban development or infrastructure. On top of that, the EUDR clashes with the EU-Mercosur trade deal, which enables the import of beef, poultry, and other commodities at low tariffs, formally excluding deforestation-linked goods, but still carrying the weight of added emissions.

This brings us to the landscapes we use without seeing them. LiveEO’s application, TradeAware, allows users to upload plots of land—whether owned, used by suppliers, or drawn manually—and receive data on potential deforestation based on satellite image comparisons over time. When a change in land cover is detected, it may indicate disturbance or a breach of the EUDR. Exact geolocation can offer a way to more consciously trace the origin of resources, making it possible to assess the real impact of consumption, often tied to lifestyles rich in goods.

The EU requires full traceability: exact geolocation, production details, compliance documents, risk assessments, and mitigation measures all need to be provided. Buying a pencil with a rubber is about to turn into an expedition. This connects to the upcoming Digital Product Passport (DPP)—a product identifier that stores open-source data about a product’s entire life cycle: its components, extraction sources, critical raw materials, disposal and recycling options, manufacturers, and more. In practice, the DPP is a digital twin of the object. It’s part of the EU’s Ecodesign for Sustainable Products Regulation, which pushes toward circular economies and includes measures like banning the destruction of unsold goods such as textiles and footwear. By 2030, every product will be required to have a DPP. But for materials like iron, steel, aluminium, electronics, chemicals, furniture, and similar, the regulation comes into force this year.

The idea of an object holding a passport isn’t new. Materials already have passports. Plants must meet phytosanitary regulations and carry passports. Pets have passports. Bred animals are tagged. All of these form part of a larger system of label-based identities. Could we extend this logic and include data about the person behind the assembly line of the product we casually pick off the shelf? Will this growing detail on even the smallest objects become part of an Io(L)T—an Internet of (Living) Things—able to reveal relationships between people and the lands of extraction? Can an object, such as a plant, be autonomous? Yes. For compound objects, the scale, however, leans towards non-autonomy. The case of digital product passports individuates the object, but the content of the passport places it in a relational involvement with others. The pencil with a rubber will no longer be just a pencil, but a set of relations defining its identity.

The social and ecological responsibility of tracing the raw materials and processes behind something as simple as a pencil with a rubber can quickly become overwhelming. At the same time, did anything truly shift when products started carrying the label Made in China? We’ve learned to filter those realities out. Are we complicit in something more than ignorance? Who carries the weight of responsibility for the complex chains of materials, land, labour, and logistics behind each product? There’s another angle to the question of passporting. What happens to those not able to attain it is not only a question of market monopolisation, but also of European hygiene and eco-purity fetishization. This further opens a debate on ecogentrification and the exclusion of all too dirty to enter.

Of course, some level of simplification is necessary. The transparency and traceability demanded by EU regulations are steps toward a more ecological and equitable system. But their real value will depend on how they’re implemented—and by whom. It remains to be seen how companies will incorporate the full story of their products and the people behind them into their branding, and what kind of weight or value a fully transparent badge will truly carry in a market still driven by convenience, speed, and price.


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