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With the European Product Act (EPA), the European Commission is planning a fundamental modernisation of European product legislation. The aim is to consolidate existing regulatory frameworks, simplify product compliance and advance digitalisation throughout the entire product lifecycle. The Digital Product Passport (DPP) could play a central role in this development.
Until now, the DPP has primarily been considered in connection with the Ecodesign for Sustainable Products Regulation (ESPR), Regulation (EU) 2024/1781. However, the EPA could significantly expand its scope. In addition to information on sustainability and the circular economy, technical documentation, compliance information and other product-related evidence could also be made available digitally in the future.
This development is also highly relevant to machinery and plant engineering, as the European Product Act could apply directly to a wide range of product groups.
It is important to consider the current legislative status: The EPA is still in the legislative process. A leaked draft that became public in autumn 2026 provides initial indications of its possible structure but does not constitute a legally binding basis for future obligations. The actual requirements will only become clearer once an official proposal has been published and the legislative process progresses.
What is the European Product Act?
With the European Product Act, the European Commission aims to modernise the existing regulatory framework for products in the European Union and place greater emphasis on digital processes.
The focus is on three existing regulatory frameworks:
These regulatory frameworks are intended to be consolidated and updated as part of the EPA.
The background to this initiative is the increasing complexity of product regulation. Different legal acts, documentation obligations and processes make it difficult for companies to maintain an overview of all applicable requirements. At the same time, digital business models, international supply chains and the growth of online trade are changing the requirements for product compliance and market surveillance.
The EPA is intended to create a coherent regulatory framework with a stronger focus on digitalisation. This could change not only how products are regulated but also how manufacturers demonstrate compliance with legal requirements.
The Digital Product Passport was originally established primarily through the ESPR, the Ecodesign for Sustainable Products Regulation, as an instrument for promoting sustainable and circular products. It is intended to make relevant product information available in a structured manner throughout the product lifecycle.
The specific requirements are generally defined for individual product groups. Not all products automatically require a DPP under the ESPR. Instead, the corresponding obligations arise from the relevant legal acts.
The EPA could change this situation. The leaked draft that became public in autumn 2026 suggests that the DPP could increasingly serve as a cross-cutting instrument of European product legislation. The focus would no longer be exclusively on sustainability information but also on the digital provision of product-related information for compliance and market surveillance purposes.
This could include, for example:
CE marking could also become more closely integrated into digital processes as part of this development.
This would give the DPP an additional function: Rather than serving solely as an instrument for providing selected sustainability information, it could become a central digital access point for product-related information and evidence of compliance.
However, the precise structure, the scope of mandatory information and the technical requirements have not yet been finalised.
Such a development could have far-reaching implications for machinery and plant engineering. Three main areas can be identified.
1. Digital product documentation and evidence of compliance
Manufacturers are already required to meet extensive requirements concerning technical documentation, conformity assessment and the provision of instructions for use.
The Machinery Regulation (EU) 2023/1230, which will apply from 20 January 2027, explicitly permits the provision of digital instructions for use under certain conditions.
If the EPA establishes the Digital Product Passport as a cross-cutting access point for product information, additional documentation obligations could arise, or existing processes could become more closely interconnected.
Manufacturers would therefore need to consider how operating instructions, declarations of conformity and other technical information can be structured, made available digitally and kept permanently accessible.
This does not necessarily mean that all documents must be stored in a single system. Rather, the key will be to clearly associate the required information with a specific product and make it available through suitable digital structures.
2. New requirements for product identification and data structures
A Digital Product Passport requires information to be reliably associated with a product. Depending on the application, this may be at model, batch or individual product level.
For machinery manufacturers, this is not an entirely new challenge. Serial numbers, product variants and technical master data are already essential elements of product management.
The challenge lies in connecting these existing structures with future requirements for digital product information.
If different regulatory requirements are to be addressed through common digital structures in the future, unique identifiers, consistent master data and standardised interfaces will become increasingly important.
Companies should therefore examine which product information is already available in a structured format, which systems provide this data and how the information can be used in the long term for different regulatory applications.
3. Components subject to DPP requirements and supply chains
A further challenge arises from the use of regulated components in machinery and plant.
One example is the digital battery passport, which, in accordance with the Battery Regulation (EU) 2023/1542, will be mandatory for certain batteries from 18 February 2027.
In the future, machinery may contain various components that are subject to their own digital information requirements. Manufacturers will therefore need to consider how the relevant information about these components can be made accessible and integrated into their own information processes.
If the EPA also establishes a more harmonised approach to digital product information, this could facilitate the connection of different product-related information systems in the long term.
How these relationships will be implemented from a technical and legal perspective remains to be seen.
How can machine manufacturers prepare for future DPP requirements?
Regardless of the final structure of the EPA, it is becoming increasingly clear that the digital provision of product information will continue to gain importance.
Various applications already exist today, including digital instructions for use, digital nameplates, service information and, prospectively, product-group-specific Digital Product Passports.
Companies must therefore consider whether these requirements should be implemented separately or whether a common technical foundation would be more appropriate.
A modular approach can offer advantages. Product identification, data structures and digital information provision can be designed in such a way that different information requirements can be added gradually.
For example, digital instructions for use and service information could be provided initially. Additional product data or information required by regulations could then be added at a later stage.
However, the technical solution must actually fulfil the applicable requirements. An existing digital documentation system does not automatically constitute a compliant Digital Product Passport under the ESPR or the Batteries Regulation. The relevant legal and technical requirements must be taken into account in each case.
Nevertheless, early digitalisation can help companies implement future adjustments more efficiently and avoid redundant data maintenance.
Although the specific requirements of the EPA have not yet been established, companies should closely monitor developments and use the remaining time to prepare.
This includes, in particular:
Companies do not need to anticipate every possible EPA requirement today. Instead, it makes more sense to establish a reliable foundation that can be adapted to future requirements.
What opportunities does the European Product Act offer beyond compliance?
The digitalisation of product documentation should not be viewed solely as an additional regulatory obligation.
Structured and centrally accessible product information can also provide practical benefits, regardless of whether a specific DPP obligation applies.
Digital instructions for use make technical information easier to access. Additional service offerings can support maintenance and repair processes. Digital communication channels enable more direct interaction between manufacturers and users.
When this information is provided through a common technical foundation, further benefits may arise in terms of data maintenance, customer service and long-term product support.
The Digital Product Passport can therefore serve not only as an instrument for fulfilling regulatory requirements but also as a building block for digitalising customer relationships and after-sales processes.
The European Product Act could significantly expand the role of the Digital Product Passport in European product legislation. While the ESPR establishes the DPP primarily as an instrument for sustainability and the circular economy, the leaked EPA draft suggests a closer connection with product compliance, technical documentation and market surveillance.
For the machinery and plant engineering industry, this could result in new requirements for the digital provision of product information. At the same time, the development offers an opportunity to harmonise existing documentation processes and address different information requirements through a common technical foundation.
Many details remain unclear. Companies should therefore distinguish between obligations that already apply and possible future requirements. Nevertheless, an early assessment of existing data structures and documentation processes is advisable.
Companies that take a strategic approach to digitalising product information today will not only establish a foundation for potential future DPP requirements but can also benefit immediately from more efficient processes and improved access to information for their customers.
Posted on: 27 October 2026
Michael Trunzer is the Managing Director and co-founder of ECHO PRM GmbH, which was founded in 2021 – a software company specialising in the smart digital product passport. Prior to this, he gained around eight years’ experience in sales and product management within the mechanical engineering sector. He is actively involved in various working groups on the Digital Product Passport (including the VDMA, VDA, CIRPASS2 and BatteryPass) and hosts the podcast “DPP Deep Dive – Knowledge on the Digital Product Passport”.
E-Mail: michael.trunzer@echoprm.com
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