# Digital product passport for machinery – status 2026 and how it differs from digital instructions for use > As of October 2026, there is no obligation to provide a digital product passport for machinery: the Machinery Regulation (EU) 2023/1230 contains no DPP, and the ESPR working plan 2025–2030 does not include machinery as a product group. What is mandatory from 20 January 2027 is something else – the instructions for use under Article 10(7), which may be provided in digital format. For machinery with certain batteries, the battery passport may become relevant from 18 February 2027. Source: https://manualpass.eu/en/guides/digital-product-passport-machinery/ · Updated: 04/10/2026 · ManualPass (https://manualpass.eu) The digital product passport (DPP) is one of the most discussed topics in European product regulation. Machinery manufacturers are regularly asked about it too, often together with the Machinery Regulation, which applies from 20 January 2027. In the process, two different obligations are easily mixed up. This guide clearly separates the two topics, summarises the status as of October 2026 and shows what you, as a manufacturer, importer or distributor of machinery, should sensibly do now. ## What is the digital product passport? The digital product passport is a product-specific digital data set under the Ecodesign for Sustainable Products Regulation (ESPR), Regulation (EU) 2024/1781. It is intended to make information on aspects such as sustainability, reparability and recyclability available along the value chain. The ESPR is a framework. For which product groups a DPP becomes mandatory and what data it must contain is only laid down by the Commission in delegated acts for individual product groups. Without such an act, there is no DPP obligation under the ESPR for a product group. ## What are digital instructions for use under the Machinery Regulation? Digital instructions for use are the instructions for use of machinery that the manufacturer provides in digital rather than paper format under Article 10(7) of Regulation (EU) 2023/1230. They serve the safe putting into service, use and maintenance of the machinery. > “The instructions for use may be provided in digital format.” > — Article 10(7), first subparagraph of Regulation (EU) 2023/1230 The digital format is permitted but not mandatory. Anyone using it must place access information on the machinery, choose a format that can be printed, downloaded and saved, and keep the instructions online for the expected lifetime, at least ten years after placing on the market. The guide [digital instructions for use](https://manualpass.eu/en/digital-instructions-for-use/) explains this in detail. !!! fakt "No DPP in the Machinery Regulation" The Machinery Regulation (EU) 2023/1230 contains no obligation to provide a digital product passport. Digital instructions for use under Article 10(7) are a separate instrument with their own requirements. ## Why are the two topics so often confused? Both instruments often work with the same visible element: a QR code on the product that leads to digital information. In addition, the timing coincides, because the Machinery Regulation applies from 2027, and the first ESPR acts and the battery passport also fall within this period. On top of that, some software providers bundle both topics in one platform. This may make sense for individual companies but does not change the legal situation. For your planning, what matters is which obligation actually applies to which product from when – and for machinery, that is currently the instructions for use under the Machinery Regulation, not a product passport. ## Digital product passport and digital instructions for use compared | Feature | Digital product passport (DPP) | Digital instructions for use | |---|---|---| | Legal basis | Ecodesign Regulation (EU) 2024/1781 plus delegated acts per product group | Article 10(7) of Regulation (EU) 2023/1230 | | Purpose | Sustainability and circularity information | Safe putting into service, use and maintenance | | Obligation or option | Mandatory only for specified product groups | Instructions for use are mandatory, the digital format is an option | | Machinery affected? | Not envisaged as a product group as of October 2026 | Yes, all machinery within the scope | | Start of application | Depending on the delegated act | 20 January 2027 | | Typical content | Product data laid down by the act | Instructions for use, safety instructions, information set out in Annex III | | Access | Via a data carrier as specified by the act | Access information on the machinery, packaging or accompanying document | In practice, this means: you need the instructions for use in any case. Whether you provide them digitally is your decision. A DPP for the machinery as a whole, on the other hand, is not envisaged as things stand today. ## What is the status of the ESPR working plan? On 16 April 2025, the Commission adopted the ESPR working plan 2025–2030. It determines for which product groups ecodesign requirements – and therefore possibly a DPP – will be developed first. The working plan names as priorities: - iron and steel as well as aluminium (intermediate products), - textiles, in particular apparel, - furniture, tyres and mattresses, - horizontal: reparability and recyclability of electrical and electronic equipment. **Machinery is not envisaged as a product group.** According to the plans, the first delegated acts (iron and steel) are to follow in 2026, textiles, tyres and aluminium in 2027. Whether and when these acts have actually been adopted has not been conclusively verified as of October 2026 – check the current status with the Commission. !!! achtung "Common misconception" “From 2027, machinery needs a digital product passport.” As things stand today, this is wrong. 2027 marks the start of application of the Machinery Regulation – with obligations regarding instructions for use and the EU declaration of conformity, not a DPP. ### Can machinery be affected indirectly? Indirectly, yes – via materials and components. If acts for steel, iron or aluminium come, your suppliers may be affected. Whether this results in information obligations for you as a machinery manufacturer depends on the content of the respective acts and is currently open. ## What applies to the battery passport? The battery passport is a separate instrument of the Batteries Regulation (EU) 2023/1542 and applies from 18 February 2027. It concerns certain batteries, for example industrial and electric vehicle batteries with a capacity of more than 2 kWh. This may become relevant for machinery if such batteries are built in, for example in battery-electric vehicles, industrial trucks or mobile machinery. Whether an obligation exists and who must fulfil it depends on the battery type, capacity and your role in the supply chain. Check this on a case-by-case basis, if necessary together with your battery supplier. !!! tipp "Practical tip" Create a list of all machine types with built-in batteries, including battery type, capacity and supplier. This lets you quickly identify where the battery passport may be an issue. ## What about the “digital rating plate”? The term “digital rating plate” is used on the market for different solutions, usually for a QR code on the machine that leads to product information. The term is not defined in the Machinery Regulation. What is legally relevant are the specific obligations: the manufacturer details on the machinery under Article 10(6), the access information for the digital instructions under Article 10(7) and, where applicable, the internet address or machine-readable code for the EU declaration of conformity under Article 10(8). A QR code can fulfil this access function. The guide [instructions for use via QR code](https://manualpass.eu/en/guides/instructions-for-use-qr-code/) explains how this works in practice. ## Are further changes coming for machinery manufacturers? A future amendment through the so-called Omnibus IV package on digitalisation is possible. Among other things, the Commission proposal of May 2025 provides that product information is to be provided digitally by default and that the EU declaration of conformity is to be accessible exclusively electronically via link or QR code without login. The Council and Parliament reached a provisional agreement on 9 June 2026. As of October 2026, this amendment has not been published in the Official Journal; the final details for machinery are open. Until publication, Article 10(7) and (8) apply in their current version. ## What can machinery manufacturers do now? Instead of waiting for a DPP, it is worth implementing the obligations that definitely apply before 20 January 2027. These steps make sense in any case: - ☐ Check for each machine type whether the instructions for use and EU declaration of conformity meet the requirements of the Machinery Regulation. - ☐ Decide whether to provide the instructions for use digitally – and if so, how to ensure access information, format and ten years of online availability. - ☐ Define a process for paper requests: free of charge and within one month under Article 10(7), third subparagraph. - ☐ Check whether your machinery can be used by non-professional users; if so, the essential safety information must be included on paper. - ☐ Clarify language versions; in Germany, German is required under Section 2 MaschinenDG. - ☐ Check machine types with built-in batteries with regard to the battery passport. - ☐ Monitor ESPR acts for steel, iron and aluminium and discuss them with suppliers. The [Machinery Regulation checklist](https://manualpass.eu/en/guides/machinery-regulation-checklist/) provides a complete overview. ## How to implement this with ManualPass ManualPass is not a Digital Product Passport, but it is DPP-ready: with the [digital nameplate](https://manualpass.eu/en/features/digital-nameplate/), each unit receives its own identification link based on the principle of IEC 61406, and the same address delivers manufacturer, type, serial number, year of construction and documents in machine-readable form as JSON. At its core, ManualPass supports the provision of documents under the Machinery Regulation: you upload instructions for use and EU declarations of conformity as PDFs and receive a fixed QR code per machine type with a public scan page in 26 languages. Versions remain archived with a SHA-256 checksum, and paper requests are recorded with deadline calculation and reminders. The [features](https://manualpass.eu/en/features/) page shows how this works in detail. ## Frequently asked questions **Will machinery need a digital product passport from 2027?** As of October 2026, no. The Machinery Regulation (EU) 2023/1230 contains no obligation to provide a digital product passport, and the ESPR working plan 2025–2030 of 16 April 2025 does not include machinery as a product group. From 20 January 2027, however, the obligations regarding instructions for use under Article 10(7) apply. **Are digital instructions for use the same as a digital product passport?** No. Digital instructions for use are a permitted format of the instructions for use under Article 10(7) of Regulation (EU) 2023/1230 and serve the safe use of the machinery. The digital product passport is an instrument of the Ecodesign Regulation (EU) 2024/1781 and only applies to product groups laid down by delegated acts. **Does the battery passport also apply to machinery?** The battery passport under the Batteries Regulation (EU) 2023/1542 applies from 18 February 2027 to certain batteries, for example industrial and electric vehicle batteries with a capacity of more than 2 kWh. It may therefore be relevant for machinery containing such batteries. Whether an obligation exists and for whom should be checked on a case-by-case basis. **Can one QR code be used both for instructions for use and for a later DPP?** Technically this is conceivable, but legally they are separate obligations with their own requirements. For a future DPP, the respective delegated acts lay down the data carrier and content; these are not in sight for machinery. Therefore plan the access information for the instructions for use according to the requirements of the Machinery Regulation first. **What should machinery manufacturers do about the DPP now?** First implement the obligations that definitely apply: instructions for use, EU declaration of conformity and their digital provision by 20 January 2027. Also check whether built-in batteries fall under the battery passport, and monitor the ESPR acts for materials such as steel and aluminium. ## Sources - [Regulation (EU) 2023/1230 (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32023R1230) - [Article 10 of Regulation (EU) 2023/1230 – obligations of manufacturers (gesetze.legal, German)](https://gesetze.legal/eu/vo_eu_2023_1230/10) - [European Commission: ESPR working plan 2025–2030](https://transition-pathways.europa.eu/news/european-commission-launches-2025-2030-plan-advance-circular-and-energy-efficient-products) - [Consolidated version of Regulation (EU) 2023/1230, as of 27 July 2026 (EUR-Lex)](https://eur-lex.europa.eu/eli/reg/2023/1230/2026-07-27/eng) --- Note: general information, not legal advice.