The Digital Product Passport (DPP) is the hot topic of the moment. Hardly any specialist publication or conference fails to cover it. But with increasing attention comes growing confusion: online, there is plenty of contradictory – and sometimes simply incorrect – information about what the DPP means for machinery and plant manufacturers. Which is why many in the industry are wondering: Do I also need to create a Digital Product Passport now? What do I have to consider? And what happens if I do nothing?
To shed some light on the matter, I spoke with Richard Merkel – the expert at the VDMA (Mechanical Engineering Industry Association) who has studied the DPP in depth and is a recognised authority on the subject.
What is the legal situation regarding the Digital Product Passport – what has already been defined?
To understand the DPP, it is essential to first understand the regulatory framework behind it. With the ESPR (Ecodesign for Sustainable Products Regulation), the basic legislative act has been in place since July 2024. This provides the foundation for the Digital Product Passport. The concrete requirements – that is, which data must be provided for which product group – will only be defined in delegated acts that will be published in stages.
Important: Anybody who wants to know exactly what is required for a specific product must always consider the basic act together with the relevant delegated act. Currently, there are no delegated acts for the DPP yet. What we do have is a published timeline, the Ecodesign for Sustainable Products and Energy Labelling Working Plan 2025–2030, which specifies when the delegated acts for each product group are expected. After a delegated act is published, a standard transition period of 18 months applies before the obligations come into force.
Which product groups are planned – and which are not?
The timeline distinguishes between energy‑related products, physical products, intermediate products and horizontal requirements. Here is an overview of the currently planned dates:
Energy‑related products (selection):
Household dishwashers, washing machines, tumble dryers, low‑temperature radiators, professional laundry and dishwashing equipment: 2026
Electronic displays: 2027
EV chargers, electric motors, refrigerators and freezers: 2028
Light sources: 2029
Welding machines, mobile phones and tablets, space heaters, tumble dryers, standby consumption: end of 2030
Physical products:
Textiles: 2027
Tyres: 2027
Furniture: 2028
Mattresses: 2029
Intermediate products:
Iron and steel: 2026
Aluminium: 2027
Horizontal requirements:
Repairability scoring: 2027
Recycled content and recyclability of electrical and electronic products: 2029
What stands out: Machinery and plants do not appear on this list. And this is the crucial point – the basis for debunking several myths surrounding the Digital Product Passport.
Myth 1: “Every manufacturer needs a DPP”
The short answer from Richard Merkel is clear: No.
A Digital Product Passport is only mandatory if a delegated act exists for the product group. Since machinery and plants – and many other product groups – are not listed among the planned delegated acts, there is no expectation that a DPP will be required for these products.
The ESPR work programme is updated every three years and extended to include additional product groups. This gives affected companies ample time to prepare.
However, this does not mean that the topic is irrelevant for machinery and plant manufacturers. Even if they do not need to create their own DPP, certain obligations may arise if they install components that do fall under DPP requirements.
Myth 2: “The standards already specify the content requirements”
This is another widespread misconception. There are currently draft standards for the Digital Product Passport – but these primarily concern the technical implementation of the DPP system: data formats, structures and exchange protocols, e.g. within harmonised standards developed by committees such as JTC 24 (a joint technical committee of CEN and CENELEC).
Richard Merkel uses a helpful analogy:
The DPP is the lorry; the content is the cargo.
The standards describe the technical requirements for the lorry – how the system must work and how information must be provided in an exchangeable format.
The delegated acts determine what the lorry must transport – the exact information and evidence to be provided.
As long as the delegated acts are missing, the “cargo” is not defined in a binding way.
Even when the required content is known, how these values must be determined is still not automatically clear. Calculating, measuring and determining specific indicators (e.g. environmental or material metrics) typically relies on additional standards providing the methodological foundation.
What machinery and plant manufacturers must nevertheless consider
Even though machinery and plants themselves will not require a DPP, responsibilities arise when components with DPP obligations are installed:
QR codes must not be removed
If a component – for example a battery – carries a DPP‑required QR code, this code must remain visible once built into a machine. The DPP must be accessible to the end user.
Due diligence obligations remain
As machinery and plant manufacturers are already responsible for compliance with the Machinery Regulation and other requirements, they must also ensure in future that components requiring a DPP actually have one. A battery without a DPP would be non‑compliant – and therefore must not be used.
Duty to inform customers? Limited.
There is currently no explicit obligation to inform customers beyond providing the DPP link or QR code. At the same time, customers often cannot realistically access all QR codes on built‑in components. This is especially impractical for raw materials like steel that undergo further processing.
It is therefore likely – and reasonable – that a requirement will be introduced to pass on all DPP links of installed components. The responsibility to check whether a DPP is required or available, and to pass on the links, would then lie with the machinery or plant manufacturer.
How DPP information must be passed on is still unclear
This could be a collection of links, a simplified DPP with references, or it may be sufficient for the QR code to remain visible on the component.
Myth 3: “The Machinery Regulation requires a DPP”
No.
The Machinery Regulation does not refer to the Digital Product Passport at all. If a digital operating manual were required, this would be explicitly stated in the Machinery Regulation or in an applicable delegated act. The DPP itself is merely the vehicle and does not impose obligations on its own.
Myth 4: “I have to keep DPP data up to date”
This is not correct in general terms.
The obligation to update lies with the manufacturer of the respective product, not with the user.
Dynamic data – such as battery charging cycles or operating hours – are intended to be maintained within the DPP, but this will only apply if required by future delegated acts. Currently, there is no delegated act that requires dynamic data.
Special case: Steel – regulated, but with open questions
Steel, as an intermediate product, is one of the groups for which a delegated act is planned (2026). Requirements similar to a material certificate are expected. However, many details remain unclear:
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Should the data be linked to individual components or expressed as percentages?
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What happens when steel is processed, e.g. during carburisation?
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Steel is regulated; the screw manufactured from that steel is not. A data sheet would refer to the applicable DPP – for example via a QR code linking to the steel manufacturer’s DPP.
Conclusion: No need to panic – but no reason to ignore the topic
Machinery and plant manufacturers currently have no obligation to create their own Digital Product Passport. The widespread panic online is largely unfounded. At the same time, companies must not overlook the issue: Anyone installing components subject to DPP requirements, such as batteries, steel, electric motors or other regulated products, must understand and fulfil their due diligence obligations.
The recommendation is clear:
Monitor the publication of delegated acts, train your purchasing teams and ensure you can identify DPP‑regulated components. Those who stay informed today will be prepared tomorrow – without rushed or unnecessary investments.
This article is based on an expert discussion between Lars Kothes and Richard Merkel, VDMA, in April 2026. Richard Merkel is responsible for the topic of the Digital Product Passport at VDMA and accompanies the regulatory developments at European level.
