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Digital Product Passport starting 2027

What companies need to know about the digital product passport

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22 Oct 2025

What companies need to know about the digital product passport

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 whirring of the machines stands a new colleague who is wearing neither overalls nor
safety shoes: the Digital Product Passport (DPP). He does not come with a
toolbox, but with a QR code and the promise to change the industry forever.
change the industry forever. Its regulatory origins lie in the EU Ecodesign Regulation ESPR 2024/1781) [1], which will gradually apply to almost all products traded in the EU.
products traded in the EU.

For many SMEs, this sounds like a distant dream of the future, but the first bars are already playing. From February 2027, the battery passport will gradually become mandatory - ushering in a new era of product transparency.
 
"Does our battery really need a passport?" asks the production manager skeptically. "It used to be enough when it was charging." The Digital Product Passport smiles diplomatically and points to the EU Battery Regulation: "Repair, recycle, conserve resources - the circular economy starts with transparency." But what does this mean for you in concrete terms? Is this just another bureaucratic hurdle from Brussels or a real opportunity for German SMEs? And how do you protect your business secrets in the process?
 
A recent survey of companies by the Federal Environment Agency and the Federal Network Agency [12] shows: Currently, only around 5 percent of German companies share environment-related data along the value chain. At the same time, around 40 percent expect an increase in bureaucracy as a result of the DPP. However, there is also good news: companies that are already familiar with the DPP are significantly more optimistic and are three times more likely to expect a reduction in bureaucracy [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 tools 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 are rarely clearly differentiated from one another. Let's imagine the three as a team that drives the digital transformation of your products and processes. Importantly, the Asset Administration Shell (AAS) has been formalized in the international standard IEC 63278-1 [2] since 2023 and thus forms a standardized basis for Industry 4.0.
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In practice, AAS and digital twins often overlap functionally: AAS is primarily a data container with a standardized structure, while the digital twin is a simulation or analysis model that uses and enriches this data [3].
 

The Digital Product Passport (DPP): more than just a QR code

As described by the German government [4] and the Chamber of Industry and Commerce [5], the DPP is a structured data set that contains all relevant information about a product over its entire life cycle. From material composition and carbon footprint to repair and disposal information - 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 a circular economy.
 
The technical basis of the DPP is defined in delegated acts to the Ecodesign Regulation (ESPR 2024/1781), which will be published in stages between 2025 and 2027 [1]. This means that the specific data requirements for various product categories will only be specified gradually. Article 10 of the ESPR ensures that product passports must beinteroperable and machine-readable - a key requirement 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 information on reparability, spare parts or proper disposal for a product." - Federal Ministry for the Environment [4]
For companies, this initially means a considerable amount of documentation. However, the Swabian Chamber of Industry and Commerce also emphasizes the opportunities: "The increased transparency provided by the DPP facilitates recycling, supports the idea of a circular economy and combats the illegal waste trade." [5] The UBA survey also shows that around 25 percent of companies see the DPP as having the potential for more ecologically sustainable decisions and more environmentally friendly product design [12].
 

The Administration Shell (AAS): The common vocabulary

To prevent the DPP from becoming a digital data tomb, a standardized structure is needed. This is where the Asset Administration Shell (AAS) comes into play. As the core of the Industry 4.0 platform [6], the AAS provides a standardized metamodel to uniformly describe the data of "assets" (i.e. machines, products or components). 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 data for the DPP in an interoperable manner. Important to understand: The AAS itself does not regulate access rights directly, but supports ABAC concepts (Attribute-Based Access Control) via its interfaces. The specific implementation of access rights remains a task of the respective system architecture, not part of the AAS core [6].
 

The digital twin (DZ): The operational brain

While the DPP and the AAS are primarily aimed at providing (rather static) information, the digital twin is the dynamic component in the trio. It is a realistic, digital image of a physical object or process that is fed with real-time data. The DZ makes it possible to monitor the condition of a battery, simulate its behavior and plan predictive maintenance. It is the operational centerpiece that increases efficiency and reduces costs.
 
Important note: The digital twin is not a mandatory component of the EU requirements, but a supplementary company tool that goes beyond the minimum regulatory 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 rather than competing

The strength of these three concepts lies in their interaction. The mnemonic is:
The Administration Shell (AAS) is the standardized "order & language", the Digital Product Passport (DPP) is the "official information" and the Digital Twin (DZ) is the "lived dynamic".
 
The AAS provides the structure and semantics for the data and defines who is allowed to see which information. The DPP uses a curated part of this data to fulfill regulatory requirements and create transparency to the outside world - without revealing company secrets. The digital twin uses the data from the AAS and enriches it with real-time information to optimize operations. The findings from the DZ 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 see the DPP as a topic for the future, it is already the present for the battery industry. The EU Battery Regulation (2023/1542) [8] makes the battery passport the first concrete use case of the Digital Product Passport. To put it more precisely: The battery passport will From February 2027, will gradually become mandatory for certain battery types. The exact data requirements will be specified in delegated acts, which are currently still in progress [8].
 
Timetable for the battery passport:
  • February 18, 2024: EU Battery Regulation enters into force
  • August 18, 2025: Coexistence with the old Battery Directive (2006/66/EC) ends
  • February 2027: Battery passport gradually becomes mandatory for certain battery types
  • Ongoing from 2027: Further data requirements are specified by delegated acts
Affected batteries:
  • All industrial batteries > 2 kWh
  • All traction batteries (electric vehicles)
  • LMT batteries (Light Means of Transport - e-bikes, e-scooters)
Each battery must then have a QR code that provides access to comprehensive information: Manufacturer, capacity, hazardous substances, CO₂ footprint, recycling information and sustainability performance. For manufacturers of e-bikes, electric vehicles, energy storage systems or industrial plants, the time to act is now.
 

Track and trace: the invisible vein of transparency

One crucial 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 Duty of Care Act (LkSG) has already significantly increased the requirements for transparency in the supply chain. Track-and-trace systems provide the necessary data to prove the origin of materials and document compliance with environmental and social standards - all information that must be mapped in the DPP.
 
Track & Trace is also intended for ESPR-relevant products and is being tested in various pilot projects. Technologies such as RFID or blockchain are optional, but have proven to be 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, won't we be giving away our competitive advantages?" We hear this concern in every consultation - and it is justified. The UBA survey shows that around 25 percent of companies fear security gaps as a result of the DPP, and around half expect high financial costs [12].
 
The good news is that the DPP does not require the disclosure of all data. In its position paper on data rooms,Plattform Industrie 4.0 emphasizes the tension between transparency and confidentiality:
 
"Digital product passports can be publicly accessible in parts, while intellectual property (IP) or wear data require stricter protection."
The legal basis for the protection of sensitive information remains the German Trade Secrets Protection Act (GeschGehG) [10], which must be harmonized with EU requirements. Companies have the right and the duty to protect their trade secrets - also in the context of the DPP.
 

The principle of staggered access rights

The solution lies in an intelligent access rights concept that is technically implemented in the AAS architecture:
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Practical example battery:
 
  • Public: "This battery contains 15 kg of lithium, has a CO₂ footprint of 85 kg CO₂e/kWh and can be 95% recycled (target value according to the EU circular economy strategy; currently even lower in pilot projects)."
  • Confidential: "The cathode consists of a proprietary NMC811 compound with optimized doping. Supplier: [name only visible to authorized partners]."
  • Internal: "The battery has completed 1,247 charge cycles, capacity is 87% of nominal, expected remaining life: 3.2 years."

Technical protection

The AAS interfaces support ABAC (Attribute-Based Access Control) concepts, which enable fine-grained control of access rights. Each submodel in the AAS can be assigned access attributes. In addition, signatures and versioning ensure data integrity and verifiability. The DPP only accesses the released, public submodels - your company secrets remain protected.

The roadmap for SMEs: a pragmatic start

The introduction of DPP, AAS and DZ does not have to be an insurmountable mammoth project. A pragmatic approach is crucial. The UBA survey shows that companies that have already dealt intensively with the DPP are much more optimistic and see more benefits [12]. Knowledge is therefore the key.
 
Phase 1: Create awareness and clarify strategy (now - Q2/2025)
Make the topic a top priority and find out about the specific 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 set up the DPP infrastructure internally or involveexternal 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 for SMEs in particular.
 

Phase 2: Develop ID strategy (Q2-Q3/2025)

Clear and consistent identification of your products and components is the basis for everything else. Determine 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 key figures
  • Maintenance: Maintenance information
  • Documentation: Technical documentation

Defineclear responsibilities and access rights for each submodel. Use the submodel templates from the Industrial Digital Twin Association (IDTA) [3], which offer standardized templates for common use cases.

Phase 4: Launch DPP pilot project (Q1/2026 - Q3/2026)

Select a product line and define which data you need and want to publish in the DPP. Implement QR code access and test the publication pipeline. Pay particular attention to the release processes for sensitive data in accordance with GeschGehG.
 

Phase 5: Launch a digital twin with clear benefits (from 2027)

Look for a specific use case with measurable success (e.g. reducing downtimes of a critical machine or optimizing the battery charging strategy). The digital twin should improve specific KPIs - such as increasing OEE (Overall Equipment Effectiveness) by 2 percentage points or reducing maintenance costs by 15%.
 

Phase 6: Establish and scale closed loop (from 2027)

Create a closed loop: findings from the digital twin flow back into the AAS as aggregated, approved key figures and from there into the DPP. This creates a learning system that enables both compliance and operational excellence.
 

Anti-patterns: you should avoid these mistakes

We know typical stumbling blocks from our consulting practice:
  • DPP as a data silo: Without a connection to the AAS, a "PDF with QR code" is created - static, not interoperable, not future-proof. Solution: Link the DPP to AAS submodels right from the start.
  • Data confusion: Company secrets inadvertently end up in the publicly accessible DPP. Solution: Establish a clear release process and a publication policy. Use the access rights mechanisms of the AAS interfaces consistently. 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 start implementation.
  • Twin without benefit hypothesis: Collect telemetry without a clear decision path. Solution: Define concrete KPIs and use cases before investing 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 mandatory program to optional extra - and a business model

The digital product passport and its technological trailblazers 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 embark on this journey now will not only meet the legal requirements, but will also secure a decisive competitive advantage.
 
The UBA survey clearly shows that knowledge makes the difference. Companies that are already familiar with the DPP see significantly more opportunities and are three times more likely to expect a reduction in bureaucracy [12]. In other words: Three out of four companies with DPP experience see opportunities instead of burdens - 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 fully document the life cycle of your products, this opens up opportunities 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 that his battery needs a passport. But if this passport helps him to save material costs, meet customer requirements, develop new service offerings and protect his trade secrets, it will quickly become an indispensable tool in his digital toolbox.
 
The clock is ticking: February 2027 is just two years away. Those who start now have a head start. Those who wait will be under time pressure.
Are you ready for the digital future of your products? Pixelmechanics will accompany you on this journey - from strategy to data protection conception to implementation. Get in touch with us!
 

Sources

[1] European Commission (2024): Regulation (EU) 2024/1781 - Ecodesign for Sustainable Products Regulation (ESPR).
[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.
[4] Federal Ministry for the Environment, Nature Conservation, Nuclear Safety and Consumer Protection (BMUV): What is a digital product passport?
[6] Platform Industry 4.0 (2024): Details of the Asset Administration Shell - Part 1.
[7] Fraunhofer IESE (2025): Digital Product Passport: Classification and Examples.
[8] European Union (2023): Regulation (EU) 2023/1542 - Battery Regulation.
[9] Federal Environment Agency (2025): Product Information 4.0 - Digital Traceability in the Circular Economy.
[10] Federal Government: Act on the Protection of Trade Secrets (GeschGehG).
[11] Gaia-X Association for Data and Cloud AISBL (2025): Position Paper: Interoperable Product Data Spaces.
[12] Federal Environment Agency & Federal Network Agency (2025): Digitalization and sustainability in business practice - results of a company survey. Status: June 1, 2025.

 

 

Tags: Integration, ERP, DPP
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