The battery passport gets most of the attention. But it's only the first step in a much larger regulatory undertaking. With the Ecodesign for Sustainable Products Regulation (ESPR, Regulation (EU) 2024/1781), the EU has established a framework that will make the Digital Product Passport (DPP) mandatory - gradually - for nearly all physical products, including industrial components, machinery, and equipment.
For product, ESG, and compliance managers in the industrial machinery sector, now is the time to lay the groundwork. Not because a deadline is looming tomorrow, but because the data a DPP will require is generated on the shop floor - and anyone who isn't capturing it in a structured way today won't be able to reconstruct it later.
What the ESPR Actually Is - and How It Differs from the Battery Regulation
The ESPR (Regulation (EU) 2024/1781) entered into force on July 18, 2024 and replaces the previous Ecodesign Directive 2009/125/EC. The key difference: the old directive was limited to energy-related products such as household appliances and heating systems. The ESPR extends the scope to cover nearly all physical goods - with only food, feed, and medicinal products explicitly excluded.
The ESPR is a framework regulation. It does not set product-specific requirements directly; instead, it empowers the European Commission to issue those requirements through delegated acts, product group by product group. This means there is no single date on which "the DPP" applies to everyone. The obligation rolls out in stages - sector by sector - once the relevant delegated act has been adopted and the transition period has elapsed.
The battery passport is a special case. It is not based on the ESPR but on the standalone EU Battery Regulation (EU) 2023/1542, making it the first binding digital product passport with a concrete deadline: February 18, 2027 - for industrial batteries above 2 kWh, EV batteries, and LMT batteries. The ESPR explicitly references it as the precedent for all future DPPs.
Battery Pass ≠ DPP under ESPR. The Battery Pass is based on Regulation (EU) 2023/1542 and applies from February 2027. The DPP under ESPR (EU) 2024/1781 will be introduced through separate delegated acts per product group. Both systems are conceptually related but legally distinct. This article does not constitute legal advice.
Which Product Groups Are Coming Next
In April 2025, the European Commission adopted the ESPR Work Plan 2025-2030, which sets the priorities for the first delegated acts. Among the product groups identified as priorities are the following:
| Produktgruppe | Erwarteter Zeitraum | Relevanz für Maschinenbau |
|---|---|---|
| Eisen & Stahl | Ab 2026 | Hoch – Grundwerkstoff für Maschinen und Anlagen |
| Aluminium | Ab 2027 | Hoch – Leichtbaukomponenten, Gehäuse |
| Elektronik / IKT | Ab 2027 | Mittel – eingebettete Steuerungen, Sensorik |
| Textilien / Bekleidung | Ab 2027 | Gering – nur indirekt relevant |
| Möbel, Reifen, Matratzen | Ab 2027/2028 | Gering |
| Maschinen & Anlagen | Folgewellen bis 2030+ | Direkt – delegierter Rechtsakt in Vorbereitung |
For companies in the machinery sector that process or place steel or aluminum components on the market, 2026 is already a relevant timeframe. Once a delegated act is published, a transition period of at least 18 months typically applies before mandatory compliance kicks in.
Important: The DPP obligation is triggered by placing a product on the EU market - regardless of where it was manufactured.
What a DPP Must Contain - and Why Manufacturing Data Is Part of It
A DPP is a structured, machine-readable dataset linked to the physical product via a data carrier (QR code, NFC, or RFID). It documents product-related information across the entire lifecycle: from development and production through use and maintenance to repair, reuse, and recycling.
The specific data fields are defined per product group by the relevant delegated act. Based on the ESPR requirements and the battery passport as a reference model, the categories that will typically be relevant are becoming clear:
- Material origin and composition - raw material sources, recycled content, substances of concern
- Carbon footprint - product-level, across the lifecycle
- Repairability and disassembly - spare parts availability, instructions, tool access
- Conformity documentation - declarations of conformity, test reports, certificates
- Manufacturing and process data - production details, quality records, traceability
That last point is new territory for manufacturers of industrial products. Information on materials, bills of materials, supplier parts, and manufacturing data that has historically been scattered across different systems must now be centrally captured, harmonized, and made available in a standardized format. Anyone still holding this data in siloed systems or spreadsheets will find a significant gap to close when building a DPP-compliant dataset.
Repairability as a Design Criterion - and the Role of Releasable Fastened Joints
The ESPR introduces up to 16 ecodesign requirements. Alongside energy efficiency and carbon footprint, these explicitly include: repairability, reusability, upgradability, and the ability to disassemble. The ESPR will progressively set durability and repairability requirements for nearly all physical goods.
This has direct implications for product design: a joint that can be released without destruction is not just a technical feature - it becomes a documentable sustainability attribute within the DPP. Whether a component can be repaired, remanufactured, or cleanly recycled depends significantly on how it is fastened.
Releasable bolted joints are an underestimated lever in this context. They enable:
- Repair without destruction - components can be replaced without damaging the overall product
- Clean-stream disassembly - material fractions can be separated and directed to recycling
- Verifiable reusability - documented fastening parameters demonstrate that a joint was released and re-established to specification
For the DPP, this means: what counts is not just the fact that a joint is releasable - but also proof that it was correctly assembled and documentation of the conditions under which it can be released.
Why Fastening Data Is Becoming Product Data
This is where the direct connection to manufacturing documentation comes in. A DPP that is meant to demonstrate repairability and circularity needs data that originates in assembly. Specifically: torque, angle of rotation, tool ID, timestamp, and result status for every individual fastening operation.
In many manufacturing environments, this data already exists today - but often not in a form suitable for a product-level lifecycle record. The DPP requirement is not simply "data exists," but rather: structured, machine-readable, traceable, and retrievable across the product's entire lifecycle.
What this means for fastening technology:
- Every fastening operation must be assignable to a unique product identifier
- Tool data must be traceable - back to the most recent calibration
- Measurement values must be exportable in open, interoperable formats
- The measurement chain must be traceable to national or international standards
GWK's OPERATOR® captures torque and angle of rotation for each fastening operation with real-time WLAN data transmission. The OPERATOR® EST01 communicates directly with the production system via PLC and Open Protocol, enabling seamless assignment of fastening data to serial numbers and production orders. EasyWin® and QuanLab Pro® software archive this data in a revision-safe, exportable format.
The QUANTEC MCS® analysis tool with fixed-point-free angle measurement provides the data foundation for development and quality assurance: which tightening method produces which clamping force? How does the joint behave under operating conditions? These insights feed into process parameters - and therefore into the documentation that a DPP will need to reflect.
DAkkS-accredited calibration - stationary at the GWK laboratory or mobile on-site - ensures that measurement values are traceable to national standards. This is not a given, but it is a prerequisite for manufacturing data to be recognized as reliable product data.
Three Action Areas for Industrial Machinery Manufacturers
The delegated acts for machinery and equipment have yet to be issued. That is not a reason to stand down - it is a window of opportunity. Laying the groundwork now avoids costly catch-up work under time pressure later.
Determine which of your product groups fall under prioritized ESPR categories — especially if you place steel or aluminum components on the market. As a supplier, you may also be affected if your customers require DPP data from you.
Map out which product-related data exists today and where: material composition, CO₂ metrics, manufacturing data, calibration records. Siloed systems and lack of traceability are the most common weak points.
Ensure that tightening data (torque, angle, tool ID, result status) is archived per product and can be exported. Traceability of the measurement chain to DAkkS-accredited calibration is a key quality requirement.
What Data Your Product Already Needs Today - A Self-Assessment
Use the interactive tool below to assess how well your current manufacturing documentation is prepared for the requirements of a Digital Product Passport.
Conclusion: Manufacturing Data Is the Foundation of the DPP
The Digital Product Passport is not an IT project you spin up shortly before a deadline. It is a mirror of a company's actual data reality - and that reality is created on the shop floor, not in the back office.
For manufacturers of industrial products, this means: the quality of fastening documentation, the traceability of the measurement chain, and the structure of manufacturing records are becoming compliance factors. Those who document comprehensively today - with traceable tools, revision-safe archiving, and DAkkS-accredited calibration - are laying the foundation for a DPP-compliant product dataset.
The delegated acts for the machinery sector have yet to be issued. But the data they will demand is being generated right now. Accuracy by GWK.
