Last updated: June 22, 2026
Frequently Asked Questions About the Digital Product Passport (DPP)
What is the Digital Product Passport (DPP)?
The Digital Product Passport (DPP) is an EU-regulated digital document that captures all relevant information about a product — from material composition through repairability to recycling instructions — for transparent supply chains.
From when is the Digital Product Passport mandatory?
The DPP is being introduced in stages: batteries from 2025, textiles and electrical products from 2026–2027. Companies should start now with their data strategy and technical implementation.
How do companies implement the Digital Product Passport technically?
Implementation requires a central PIM system, standardized data formats (GS1, EPCIS) and an interface to EU-compliant DPP registries. PixelMechanics supports strategy, architecture and implementation.
DPP, administration shell and digital twin – the
practical guide for SMEs
It's Monday morning in a German production hall. Between the smell of coffee and the humming of the machines stands a new colleague who wears neither overalls nor safety shoes: the Digital Product Passport (DPP). It doesn't arrive with a toolbox, but with a QR code and the promise to change industry forever. Its regulatory origin lies in the EU Ecodesign Regulation ESPR 2024/1781) [1], which applies gradually from then on to almost all products traded in the EU.
For many mid-sized companies this sounds like distant future music, but the first bars are already playing. From February 2027, the battery passport will gradually become mandatory – and with it a new era of product transparency begins. "Does our battery really need a passport?" the production manager asks skeptically. "In the past it was enough if it charged." The Digital Product Passport smiles diplomatically and points to the EU Battery Regulation: "Repair, recycle, conserve resources – the circular economy begins with transparency." But what does that mean concretely for you? Is this just another bureaucratic hurdle from Brussels or a real opportunity for the German SME sector? And how do you protect your trade secrets in the process? A recent company survey by the German Environment Agency and the Federal Network Agency [12] shows: currently only about 5 percent of German companies share environment-related data along the value chain. At the same time, about 40 percent expect an increase in the bureaucratic effort due to the DPP. But there is also good news: companies that already know the DPP are significantly more optimistic and three times more often expect a decrease in bureaucratic effort [12]. In this article we shed light on the jungle of terms surrounding the Digital Product Passport, the administration shell (AAS) and the digital twin – and show you how you can use these instruments as a strategic advantage without disclosing your sensitive data.Three terms, one goal: the digital future of production
The terms DPP, AAS and digital twin are often mentioned in the same breath, but rarely clearly distinguished from one another. Let's imagine the three as a team driving the digital transformation of your products and processes forward. Important here: the Asset Administration Shell (AAS) has been formalized since 2023 in the international standard IEC 63278-1 [2] and thus forms a standardized basis for Industry 4.0..png)
In practice, AAS and digital twin often overlap functionally: the AAS is primarily a data container with a standardized structure, while the digital twin represents a simulation or analysis model that uses and enriches this data [3].
The Digital Product Passport (DPP): more than just a QR code
The DPP is, as described by the German government [4] and the IHK [5], a structured data set that contains all relevant information about a product over its entire lifecycle. From the material composition through the CO₂ footprint to repair and disposal instructions – the DPP makes products transparent and traceable. This is not an end in itself, but a direct response to the demands of the European Green Deal for more sustainability and circular economy. The technical basis of the DPP is defined in delegated acts on the Ecodesign Regulation (ESPR 2024/1781), which will be published gradually between 2025 and 2027 [1]. This means: the concrete data requirements for various product categories will only be specified gradually. Article 10 of the ESPR ensures that product passports must be provided interoperably and machine-readable – a central prerequisite for the functioning of the circular economy [1]. "The Digital Product Passport is a data set that summarizes the components, materials and chemical substances or also information on repairability, spare parts or proper disposal for a product." – Federal Environment Ministry [4] For companies this initially means considerable documentation effort. But the IHK Schwaben also emphasizes the opportunities: "The increased transparency through the DPP facilitates recycling, supports the idea of the circular economy and combats illegal waste trade." [5] The UBA survey also shows: about 25 percent of companies see in the DPP the potential for more ecologically sustainable decisions and more environmentally friendly product design [12].The administration shell (AAS): the common vocabulary
So that the DPP does not become a digital data grave, a uniform structure is needed. This is where the administration shell (Asset Administration Shell, AAS) comes into play. As the core of the Plattform Industrie 4.0 [6], the AAS provides a standardized meta-model to describe the data of "assets" (i.e. machines, products or components) uniformly. It is the translator between the various IT systems in your company (ERP, MES, PLM) and those of your partners and customers. The AAS ensures that everyone speaks the same language. It is the technical basis for providing and exchanging the data for the DPP interoperably. Important to understand: the AAS itself does not directly regulate access rights, but supports ABAC concepts (Attribute-Based Access Control) via its interfaces. The concrete implementation of access rights remains a task of the respective system architecture, not part of the AAS core [6].The digital twin (DT): the operational brain
While the DPP and the AAS are aimed primarily at providing (rather static) information, the digital twin is the dynamic component in the trio. It is a true-to-life, digital replica of a physical object or process that is fed with real-time data. The DT makes it possible to monitor the state of a battery, simulate its behavior and plan predictive maintenance. It is the operational heart that increases efficiency and lowers costs. Important note: The digital twin is not necessarily part of the EU requirements, but a complementary company tool that goes beyond the regulatory minimum requirements [7]. While the DPP ensures compliance, the digital twin creates operational added value. However, it can be technically integrated via AAS submodels if companies wish – the architecture is designed for this.The interplay: complementary instead of competing
The strength of these three concepts lies in their interplay. The mnemonic is: The administration shell (AAS) is the standardized "order & language," the Digital Product Passport (DPP) the "official information" and the digital twin (DT) the "lived dynamics." The AAS provides the structure and semantics for the data and defines who may see which information. The DPP uses a curated part of this data to meet regulatory requirements and to create transparency to the outside – without disclosing trade secrets. The digital twin uses the data from the AAS and enriches it with real-time information in order to optimize operations. The insights from the DT can in turn flow back into the AAS and thus enrich the DPP with valuable but released usage data.The battery passport: pioneer and practical example
While many companies still regard the DPP as a topic for the future, for the battery industry it is already the present. The EU Battery Regulation (2023/1542) [8] makes the battery passport the first concrete use case of the Digital Product Passport. To put it precisely: the battery passport will become mandatory in stages from February 2027 for certain battery types. The exact data requirements are being specified in delegated acts that are currently still in progress [8]. Timeline for the battery passport:- February 18, 2024: EU Battery Regulation comes into force
- August 18, 2025: coexistence with the old Battery Directive (2006/66/EC) ends
- February 2027: battery passport becomes mandatory in stages for certain battery types
- Ongoing from 2027: further data requirements are specified through delegated acts
- All industrial batteries > 2 kWh
- All traction batteries (electric vehicles)
- LMT batteries (Light Means of Transport – e-bikes, e-scooters)
Track and trace: the invisible artery of transparency
A decisive aspect that runs through all three concepts is track and trace. The seamless traceability of products and components along the entire supply chain is the basis for a functioning DPP. The German Supply Chain Due Diligence Act (LkSG) has already significantly increased the requirements for transparency in the supply chain. Track-and-trace systems deliver the necessary data to prove the origin of materials and to document compliance with environmental and social standards – all information that must be represented in the DPP. Track & trace is also planned for ESPR-relevant products and is being tested in various pilot projects. Technologies such as RFID or blockchain are optional here, but have proven particularly robust and tamper-proof in practice [9]. They are the link between the physical product and the digital passport. The crucial question: data protection and trade secrets "If we have to disclose all data, aren't we then giving away our competitive advantages?" We hear this concern in every consulting conversation – and it is justified. The UBA survey shows: about 25 percent of companies fear security gaps due to the DPP, and about half expect a high financial effort [12]. The good news: the DPP does not require the disclosure of all data. The Plattform Industrie 4.0 emphasizes in its position paper on data spaces the tension between transparency and secret protection: "Digital product passports can be partly publicly accessible, while intellectual property (IP) or wear data need stricter protection." The legal basis for the protection of sensitive information remains the Act on the Protection of Trade Secrets (GeschGehG) [10], which must be harmonized with the EU requirements. Companies have the right and the duty to protect their trade secrets – also in the context of the DPP.The principle of tiered access rights
The solution lies in an intelligent access rights concept that is technically implemented in the AAS architecture:-1.png)
Practical example battery:
- Public: "This battery contains 15 kg of lithium, has a CO₂ footprint of 85 kg CO₂e/kWh and can be recycled to 95% (target value according to the EU circular economy strategy; currently still lower in pilot projects)."
- Confidential: "The cathode consists of a proprietary NMC811 mixture with optimized doping. Supplier: [name visible only to authorized partners]."
- Internal: "The battery has gone through 1,247 charging cycles, the capacity is at 87% of the nominal value, expected remaining service life: 3.2 years."
Technical safeguarding
The AAS interfaces support ABAC concepts (Attribute-Based Access Control) that enable fine-grained control of access rights. Each submodel in the AAS can be provided with access attributes. In addition, signatures and versioning ensure data integrity and verifiability. The DPP accesses only the released, public submodels – your trade secrets remain protected.The roadmap for SMEs: start pragmatically
The introduction of DPP, AAS and DT does not have to be an insurmountable mammoth project. A pragmatic approach is decisive. The UBA survey shows: companies that have already engaged intensively with the DPP are significantly more optimistic and see more advantages [12]. Knowledge is therefore the key. Phase 1: Create awareness and clarify strategy (now – Q2/2025) Make the topic a matter for top management and inform yourself about the concrete requirements for your industry. The first product categories that will be affected from 2027 are batteries, textiles and electronics. Check whether your products fall into these categories. Strategic decision: Check whether you want to build the DPP infrastructure internally or involve external DPP service providers (DPP-as-a-Service). The ESPR explicitly allows the use of service providers (Article 32) [1], which can be a pragmatic option especially for SMEs.Phase 2: Develop ID strategy (Q2-Q3/2025)
A unique and consistent identification of your products and components is the basis for everything else. Define how you identify product models, series, batches and individual objects. Use standardized identifiers (URN, UUID, GTIN).Phase 3: Establish AAS as the backbone (Q3/2025 – Q4/2025)
Start with a core set of 3-5 submodels of the administration shell:- Identity/nameplate: basic data of the product
- Bill of Materials (BoM): material composition
- Sustainability: sustainability metrics
- Maintenance: maintenance information
- Documentation: technical documentation
Define clear responsibilities and access rights for each submodel. Use the submodel templates of the Industrial Digital Twin Association (IDTA) [3], which offer standardized templates for common use cases.
Phase 4: Start DPP pilot project (Q1/2026 – Q3/2026)
Choose a product line and define which data you must and want to publish in the DPP. Implement the QR code access and test the publication pipeline. Pay particular attention to the release processes for sensitive data in accordance with GeschGehG.Phase 5: Start the digital twin with clear benefit (from 2027)
Look for a concrete use case with measurable success (e.g. reducing the downtime of a critical machine or optimizing the battery charging strategy). The digital twin should improve concrete KPIs – for example increase OEE (Overall Equipment Effectiveness) by 2 percentage points or reduce maintenance costs by 15%.Phase 6: Establish closed loop and scale (from 2027)
Create a closed control loop: insights from the digital twin flow back as aggregated, released metrics into the AAS and from there into the DPP. This creates a learning system that enables both compliance and operational excellence.Anti-patterns: these mistakes you should avoid
From our consulting practice, we know typical stumbling blocks:- DPP as a data silo: Without connection to the AAS, a "PDF with QR code" arises – static, not interoperable, not future-proof. Solution: couple the DPP to AAS submodels from the start.
- Data confusion: Trade secrets accidentally end up in the publicly accessible DPP. Solution: establish a clear release process and a publication policy. Consistently use the access rights mechanisms of the AAS interfaces. Document which data falls under the GeschGehG.
- ID chaos: Product, series and individual asset IDs are inconsistent, different systems use different identifiers. Solution: develop a central ID strategy before you begin implementation.
- Twin without a benefit hypothesis: Collecting telemetry without a clear decision path. Solution: define concrete KPIs and use cases before you invest in the infrastructure.
- Vendor lock-in: Dependence on proprietary DPP platforms. Solution: pay attention to open standards (AAS, IDTA submodels) and interoperability with initiatives such as Gaia-X [11].
Conclusion: from compulsory program to freestyle – and to business model
The Digital Product Passport and its technological enablers are far more than a regulatory obligation. They are the key to more efficient processes, new business models and a more sustainable economy. Companies that set off now will not only meet the legal requirements, but also secure a decisive competitive advantage. The UBA survey clearly shows: knowledge makes the difference. Companies that already know the DPP see significantly more opportunities and three times more often expect a decrease in bureaucratic effort [12]. Put differently: three out of four companies with DPP experience see opportunities instead of burden – knowledge is the decisive success factor. The biggest hurdle is therefore not the technology, but the information gap. In the medium term, the DPP supports new business models such as product-as-a-service or circular economy approaches. If you can document the lifecycle of your products seamlessly, possibilities open up for leasing, take-back and refurbishment models. Compatibility with industry initiatives such as Gaia-X [11] ensures that your data remains usable in interoperable, sovereign data spaces. The production manager from our opening story may be skeptical about whether his battery needs a passport. But if this passport helps him save material costs, meet customer requirements, develop new service offerings and protect his trade secrets in the process, it will quickly become an indispensable tool in his digital toolbox. The clock is ticking: Until February 2027 there are only two years left. Those who start now have a head start. Those who wait will come under time pressure. Are you ready for the digital future of your products? Pixelmechanics accompanies you on this path – from strategy through data protection design to implementation. Get in touch with us!Sources
[1] European Commission (2024): Regulation (EU) 2024/1781 – Ecodesign for Sustainable Products Regulation (ESPR). https://eur-lex.europa.eu/eli/reg/2024/1781/oj [2] IEC 63278-1 (2023): Asset Administration Shell for Industrial Applications – Part 1: Administration Shell Structure. International Electrotechnical Commission. [3] Industrial Digital Twin Association (IDTA) (2024): Submodel Templates. https://industrialdigitaltwin.org/en/content-hub/submodels [4] Federal Ministry for the Environment, Nature Conservation, Nuclear Safety and Consumer Protection (BMUV): What is a digital product passport? https://www.bundesumweltministerium.de/faq/was-ist-ein-digitaler-produktpass [5] IHK Schwaben: The Digital Product Passport. https://www.ihk.de/schwaben/produktmarken/energie/kreislaufwirtschaft/der-digitale-produktpass-6195430 [6] Plattform Industrie 4.0 (2024): Details of the Asset Administration Shell – Part 1. https://www.plattform-i40.de/IP/Redaktion/EN/Downloads/Publikation/Details_of_the_Asset_Administration_Shell_Part1_V3.pdf [7] Fraunhofer IESE (2025): Digital Product Passport: Classification and Examples. https://www.iese.fraunhofer.de/blog/digitaler-produktpass-beispiel-dpp/ [8] European Union (2023): Regulation (EU) 2023/1542 – Battery Regulation. https://eur-lex.europa.eu/eli/reg/2023/1542/oj [9] German Environment Agency (2025): Product Information 4.0 – Digital Traceability in the Circular Economy. https://www.umweltbundesamt.de/themen/produktinformation-40 [10] Federal Government: Act on the Protection of Trade Secrets (GeschGehG). https://www.gesetze-im-internet.de/geschgehg/ [11] Gaia-X Association for Data and Cloud AISBL (2025): Position Paper: Interoperable Product Data Spaces. https://gaia-x.eu/what-is-gaia-x/ [12] German Environment Agency & Federal Network Agency (2025): Digitalization and Sustainability in Business Practice – Results of a Company Survey. As of: June 1, 2025.Further resources
- Reference: Bosch Rexroth – Industry 4.0 & digital manufacturing
- Reference: Nicotra Gebhardt – Digitalization in mechanical engineering
- Reference: ETO – Technology in the SME sector
- Reference: Max Bögl – Digital transformation in construction
- Reference: va-Q-tec – Sustainability & digitalization
- Whitepaper: E-commerce automation in manufacturing
