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Through the Regulation (EU) 2024/1781, known as the Ecodesign for Sustainable Products Regulation, or ESPR for short), the European Union aims to strengthen the circular economy and make products more sustainable throughout their entire life cycle. A key instrument of this strategy is the Digital Product Passport (DPP), which is intended to serve as a digital complement to the physical product in future. Its purpose is to provide relevant information on materials, sustainability, reparability and other product characteristics in a structured manner. This is based on the requirements of the ESPR and other regulations, such as the Battery Regulation (Regulation (EU) 2023/1542).
Although mechanical and plant engineering is not initially among the prioritised product groups in the first wave of implementation, the sector will be affected by the Digital Product Pass in a variety of ways. In addition to potential direct regulation, there will be particular implications arising from integration into supply chains and from the use of components subject to the DPP requirement in end products in future.
The regulatory framework of the Digital Product Passport
The ESPR is a framework regulation and initially sets out general requirements for almost all physical products placed on the market within the European Union. However, the specific requirements for individual product groups will only be laid down via so-called delegated acts. This will result in a gradual, product-group-specific definition of the requirements regarding performance, resource efficiency and the provision of information.
In addition to the Ecodesign Regulation, there are other sets of regulations that also provide for digital product passports. These include, in particular, the Battery Regulation, which will require a digital battery passport for certain types of batteries from February 2027. For further regulations, for example, toys, construction products, detergents and vehicles the DPP is also already in the pipeline.
Furthermore, the European Commission regards the Digital Product Passport as a key future tool for the provision and disclosure of product information within European product legislation. In the long term, numerous information and documentation requirements are to be consolidated within this system. In particular, with regard to the European Product Act (EPA), expected as a draft in autumn 2026, discussions are currently underway (as of July 2026) regarding a significantly more extensive introduction of the DPP.
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What is the Digital Product Passport?
The Digital Product Passport is a structured dataset that makes information about a product available throughout its entire life cycle. This includes, for example, details of materials, chemical constituents, repair options, spare parts and information on proper disposal. The data can be used during manufacture, whilst the product is in use, and at the end of its life.
Access to the Digital Product Passport is provided via the physical product using a QR code, NFC tag or similar technologies.
The aim of the DPP is to improve transparency and traceability whilst supporting compliance with regulatory requirements. Various stakeholders, such as manufacturers, distributors, operators, repair shops, waste management companies and public authorities, are each to be granted access to the information relevant to them. This makes the Digital Product Passport a central information medium throughout the entire value chain.
Why is the mechanical and plant engineering sector affected by the DPP?
For companies in the mechanical and plant engineering sector, there are essentially three different scenarios in which they may be affected.
Direct impact
A direct obligation arises as soon as a delegated act or a standalone regulation exists for a specific product group that mandates a Digital Product Passport. The first product groups have already been prioritised. Further groups will follow in the coming years. Manufacturers and those responsible for placing products on the market are then responsible for creating, maintaining and providing the DPP data.
Indirect impact through data provision
For the mechanical and plant engineering sector, the indirect impact is particularly relevant. If, for example, a machine is used in future to produce regulated products such as textiles or other goods subject to the DPP, certain production data may be required. This includes, for example, information on energy consumption or emissions. Customers may need this data to meet the requirements for their own Digital Product Passports. As a result, the provision of such information is increasingly becoming a requirement within the supply chain.
Impact of regulated components
Another scenario arises from the use of components subject to DPP requirements within machinery and plant. These include, for example, batteries, displays or electric motors. In future, the question will arise as to how the product passports for these components must be made accessible within an overall system. Although not all the details have yet been clarified, it is already clear today that transparency requirements along the supply chain will increase significantly.
What information will be provided in the DPP in future?
The specific content of the Digital Product Passport will be defined on a product-group-specific basis via delegated acts. In principle, information should be provided that reflects both the performance requirements and the information requirements of a product. This may include, for example:
The data is to be tailored to the characteristics of the product group and to the needs of the various user groups.
What is the technical structure of the Digital Product Passport?
Access to the Digital Product Passport is generally product-specific. Users can access the stored information directly via a QR code, NFC tag or similar technologies. The data itself is stored decentrally.
Due to the decentralised nature of the DPP system, each distributor or manufacturer is independently responsible for implementing the system, though they may outsource this task to a third-party service provider (DPP-as-a-Service Provider).
In addition, a European DPP register and a central web portal are planned. These are intended, in particular, to enable public authorities, market surveillance bodies and other stakeholders to access basic information. The first version of the DPP register will be available in July 2026 and will then be continuously expanded.
Open standards and interoperability are of central importance for the technical implementation. The aim is to avoid dependence on individual providers and to enable the smooth exchange of information between different systems.
Based on the Ecodesign Regulation and the Battery Regulation, CEN CENELEC has developed eight harmonised standards for the technical DPP system. The first six of these standards have been available since the end of May 2026 and must now be integrated into software systems for Digital Product Passports – either by the distributor themselves or by a DPP-as-a-Service provider.
What are the challenges involved in implementing the DPP in the mechanical and plant engineering sector?
he introduction of the Digital Product Passport presents companies with numerous organisational and technical challenges. Relevant information is often stored in different systems and data sources. Data silos, a lack of interfaces and inconsistent master data make it difficult to provide the information in a structured manner.
At the same time, collaboration with suppliers will become increasingly important. Much of the required data can only be collected across the entire value chain. Companies must therefore lay the groundwork at an early stage to make the relevant information available and exchange it in a standardised manner.
In addition to technical issues, organisational changes are also necessary. Staff from design, production, technical documentation, service and sales must understand the future requirements and integrate them into their processes. Developing the relevant skills will therefore be a key factor for success.
Why should companies start preparing for the DPP today?
Even though the specific impact on certain product groups will only be clarified in the coming years through delegated acts, the general direction is already becoming apparent. Companies should use the time remaining to gradually further develop their data structures and processes.
This includes, in particular, the introduction of standardised product structures, the identification of relevant data sources, the assessment of existing IT systems, and the early involvement of suppliers. At the same time, it is advisable to analyse potential interfaces and future integration options. This will make subsequent adjustments significantly more efficient.
What opportunities does the DPP offer beyond mere compliance?
The Digital Product Passport should not be viewed solely as a regulatory obligation. Rather, it offers the opportunity to digitise and further develop existing information and service processes.
Structured product data can improve internal processes and increase transparency throughout the entire value chain. At the same time, new opportunities arise for service, maintenance and spare parts management. Digital documentation, additional product information or modern communication channels can enhance customer value and boost the efficiency of after-sales processes. And all these voluntary options are already available today, even if a company’s own products are not yet directly regulated under the Ecodesign Regulation.
The Digital Product Passport is set to become an integral part of European product regulation in the coming years. Although many specific requirements have yet to be finalised, it is already clear that the mechanical and plant engineering sector will be affected by the future regulations, both directly and indirectly.
In addition to regulatory requirements, the provision of data throughout the supply chain and the handling of components subject to the Digital Product Passport will become particularly important. Companies should therefore start early to align their data structures, processes and system landscapes with the upcoming requirements.
To view the Digital Product Passport solely as an additional reporting obligation is to miss the point. Rather, it presents an opportunity to sustainably improve transparency, digitalisation and efficiency throughout the entire product life cycle, thereby strengthening competitiveness in the long term – and to do so right from the start.
Posted on: 29 June 2026