Industry · Machinery & Plant Engineering
Straight talk first: machinery is not in the first ESPR working plan of April 2025 – there is no dedicated machinery passport act for now. That is no all-clear, though. The DPP reaches machinery companies from three directions: through the materials steel and aluminium, through built-in industrial batteries from 18 Feb 2027 – and through customers who already demand CO₂ and material data. Build the data foundation now and you are prepared before any obligation catches up with you.
01 — Situation
Search for "digital product passport machinery" and you will often get two wrong answers: scaremongering ("the machinery passport is coming in 2027!") or an all-clear ("does not affect us"). Neither is true. The facts: the first working plan under the ESPR Regulation (EU) 2024/1781 of April 2025 prioritises intermediate products such as iron & steel and aluminium, plus end products such as textiles, tyres and furniture – machinery and plant are not on it. A delegated act for machinery is currently not scheduled.
Why the topic belongs on the table anyway: the Digital Product Passport is driven by materials and supply chains. A machine tool consists largely of steel and aluminium – precisely the two material categories whose delegated acts are expected first (steel Q4 2026, aluminium 2027, indicative). Once the steel passport arrives, data duties arise along the chain: whoever processes passport-covered material must be able to record, link and pass on origin, recycled-content and CO₂ data. The EU DPP registry has been live since 20 July 2026 – the infrastructure already exists.
Add two further flanks: from 18 Feb 2027 the battery passport under the Battery Regulation (EU) 2023/1542 applies to industrial batteries above 2 kWh – covering many batteries built into automated guided vehicles, mobile machinery or UPS systems. And independently of any DPP obligation, customers from passport-covered industries as well as CBAM- and CSRD-driven procurement departments already request product-level carbon footprints and material data today. For machinery, the data work does not start with a dedicated delegated act – it has long since started.
02 — Exposure
Not as the addressee of a dedicated delegated act – but as processor, user and supplier:
01
The delegated acts for iron & steel (expected Q4 2026) and aluminium (expected 2027) hit the materials machines are made of. Steel and aluminium passports mean data flows along the chain: goods receipt, batch allocation, hand-over to customers – your ERP must be able to record and link passport data.
02
The battery passport applies from 18 Feb 2027 to industrial batteries above 2 kWh – even when built into your machine. If you build AGVs, mobile machinery or battery-buffered plant, you need the passport data from your battery supplier and a clean link between machine and battery.
03
Automotive, construction, electronics: your customers face their own passport and reporting duties – and pass data requirements down the chain. CBAM prices the emissions of steel and aluminium imports, CSRD reporting triggers supply-chain queries. Those who can deliver CO₂ and material data per product stay on the supplier list.
03 — Data foundation
Whenever a dedicated act may come: these data categories fall due anyway through material passports, the battery passport and customer requirements – and they need years of lead time, not weeks:
Which steel and aluminium grades, which alloys, which plastics sit in which assembly? Bills of materials must be deepened from part number to material level – the precondition for allocating steel and aluminium passport data at all.
Structured requests to material and component suppliers: recycled content, origin, in future the passport identifiers themselves. Write data requirements into framework contracts and specifications now and you will not pay for retroactive research later.
For industrial batteries above 2 kWh from 18 Feb 2027: passport identifier, capacity, carbon footprint, due-diligence data from the cell or pack supplier – plus the link to your machine's serial number.
From corporate to product carbon footprint: customers, CBAM logic and future passport requirements demand emission data per machine or per component – not per site.
Spare-part lists, disassembly information, maintenance history: machinery is traditionally strong here – structured and machine-readable, it becomes a competitive edge once horizontal repairability requirements arrive.
Serial-number logic, nameplate, QR or RFID marking: the identifier system under EN 18219 can be aligned with your own identification logic today – see DPP standards.
That is exactly where machinery readiness begins: taking stock of data assets, prioritising gaps, setting up a product-specific data model. In a short call we will show you where you stand and what makes sense now.
04 — Timeline
Dates for delegated acts are indicative (as of August 2026) – the registry and battery passport are fixed:
20 Jul 2026 ✓ in force
The EU's central registration infrastructure has been in operation since 20 July 2026 – including a testing environment. The technical foundation for all product passports that follow exists.
Q4 2026 expected
The first material act hits the base material of almost every machine. Steel passport data travels along the chain – processors must be able to record and allocate it.
18 Feb 2027 fixed
Industrial batteries above 2 kWh need the passport – including those built into AGVs, mobile machinery and plant. The first fixed DPP date with direct machinery relevance.
2027 expected
Machinery's second core material gets its delegated act – recycled-content, origin and CO₂ data for aluminium components become chain-relevant.
Mid-term expected
Cross-product-group rules on repairability and durability may reach machinery too – the timing is open, the direction is not.
05 — Industrie 4.0
Hardly any industry brings better preconditions for the product passport than machinery – they just go by different names. The Asset Administration Shell (AAS, German: Verwaltungsschale) is, as an Industrie 4.0 standard, exactly what the DPP demands technically: a machine-readable, structured digital twin of an asset with standardised submodels – for nameplate data, technical properties or the carbon footprint, for instance. If you already describe your products via Asset Administration Shells, or plan to, you are building the very data architecture a future product passport requires.
The VDMA (the German machinery association) and other Industrie 4.0 initiatives are also working on orientation and standards around the Digital Product Passport in machinery and plant engineering – from guidance to aligning AAS submodels with DPP requirements. For you this means: the question is not whether to wait for a "machinery passport", but whether your product data already exists in a structure that can dock onto the Asset Administration Shell, EN 18219 and the material passports.
Pragmatically: investing in structured product data is not a bet on an uncertain delegated act. It pays off three times – towards the obligations that arrive anyway via steel, aluminium and batteries, towards your customers' data requirements, and towards your own digitalisation (spare-parts business, service, retrofit). How to set this up on the systems side is covered on our DPP data management page.
06 — FAQ
Currently not as a product group of its own: the first ESPR working plan of April 2025 contains no delegated act for machinery. Indirectly, however, yes – three times over: through the materials becoming passport-covered, steel (act expected Q4 2026) and aluminium (expected 2027), through the battery passport for built-in industrial batteries from 18 Feb 2027, and through customers demanding CO₂ and material data per product. All dates for delegated acts are indicative.
From 18 Feb 2027, traction batteries, LMT batteries and industrial batteries above 2 kWh need a battery passport under the Battery Regulation (EU) 2023/1542 – even when the battery sits inside a machine, such as an automated guided vehicle or mobile machinery. You will then need the passport data from your battery supplier and a clean link between battery passport and machine serial number. Whether your products are affected is what we clarify in the applicability check.
Yes, considerably. The Asset Administration Shell structures product data exactly the way a product passport requires: machine-readable, standardised, with submodels for nameplate data or the carbon footprint, for example. Building AAS structures lays the data plumbing that DPP requirements can dock onto later. What matters is keeping the data model and identifier logic compatible with EN 18219 and the coming material passports from the start.
Three things: (1) deepen bills of materials to material level and identify the steel/aluminium and battery share in the portfolio, (2) collect supplier data in a structured way – recycled content, origin, CO₂ data – and write data duties into new contracts, (3) move carbon footprints from site level to product level. That way you serve customer requests today and passport obligations tomorrow from the same data foundation.
It cannot be ruled out – the ESPR is designed as a framework that is gradually extended to further product groups, and horizontal requirements on repairability and durability may reach machinery even without a dedicated act. But no date exists, and speculation helps no one. The solid planning basis is the facts (registry live since 20 July 2026, battery passport mandatory 18 Feb 2027) and the expected material acts – preparation for those pays off regardless of what comes later.
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