The EU Digital Product Passport for industrial assets: how in-use data could complete the picture

Over the coming years, almost every product sold in the EU will need to carry a digital identity card alongside it, summarising what it is made of, how it can be repaired, and what happens to it at end of life. That is the idea behind the EU Digital Product Passport (DPP), introduced under the Ecodesign for Sustainable Products Regulation (ESPR), and it is one of the more consequential shifts coming out of EU industrial policy.  Batteries are the only product group with a passport already in regulation today. For everything else, the framework exists but the specifics are still being worked out, category by category, through delegated acts. None of the industrial product groups is settled yet, making now the moment to think out loud about what a good DPP could look like and where in-use data fits in. 

The DPP is the data backbone of ESPR. As described by the European Commission, it is a structured collection of product-related data with a predefined scope, agreed ownership and access rights, conveyed through a unique identifier. The system is decentralised, with a central registry, and the data sits on the asset itself, typically reached through a data carrier such as a QR code.

A few principles are worth keeping in mind. The data must be machine-readable and built on open standards. Identifiers are unique and persistent. Access follows a need-to-know logic, set per product group. The economic operator placing the product on the market is responsible for the passport. The ESPR aspects in scope include durability, reparability, recycled content, the possibility of remanufacturing and recycling, substances of concern, and environmental impacts.

Two distinct workstreams are running in parallel, and it is useful to keep them apart. The technical formats and protocols of the DPP system, things like data carriers, unique identifiers and interoperability, are being defined through a standardisation process at CEN, CENELEC and ETSI. The actual data fields each product group must include are being set by the Commission through delegated acts.

Concretely, that translates into fields such as the product’s unique identifier, a bill of materials with declared substances of concern, recycled-content share, repair and maintenance instructions, expected lifetime, end-of-life instructions, and a product carbon footprint. The exact list will differ by product group.

The Commission’s Joint Research Centre has recently published a methodology for defining data requirements for the DPP under ESPR, which sorts candidate data fields into essential, strongly recommended and voluntary categories based on a transparent value-versus-effort assessment. It is a useful reference for pondering where in-use data might land in each future delegated act.

Batteries are operational under their own regulation, and a draft DPP for steel is currently open for industry comment. For other industrial categories, the delegated acts defining the data fields have not landed yet, which is why this article is best read as a working hypothesis from Sensolus.

Most of the data a future DPP will ask for already lives in someone’s system. Design data tends to sit in product lifecycle systems. Build data sits in manufacturing and ERP. Material composition comes from suppliers, increasingly in a structured form. The factory-gate carbon footprint is doable, even where methodology is still maturing.

The harder part is everything that happens after the asset is shipped. Real utilisation, meaning operating hours, duty cycles, idle time versus productive time. Environmental exposure, including shock events, temperature swings and vibration. Location history. Maintenance reality, which often diverges from the maintenance plan in the manual. And end-of-first-life signals, which tell a future owner whether an asset is a candidate for refurbishment, resale or recycling.

This data does not live inside the manufacturer’s four walls. It lives on the asset, wherever the asset happens to be. That is the in-use phase, and it is what we have spent the last twelve years instrumenting.

The use case where in-use data could add the most value, in our view, is remanufacturing and secondary markets. By extension, the same logic applies to any industrial product category with a meaningful secondary-market or refurbishment angle.

A remanufacturer will only pay a fair price for a used component if they trust its history. How many hours did it run? Did it ever see a shock event above the threshold? Was it stored outside for six months? Without an answer, the buyer assumes the worst and prices accordingly, or refuses to bid at all. In-use data turns “we think this gearbox has 4,000 hours on it” into a verifiable record.

To be clear, we do not expect in-field operational data to be mandatory in the first wave of delegated acts. The early DPPs will lean on static information: material declaration, components, repairability, and compliance documentation. Where we do think the conversation could usefully move is for product groups whose policy goal is explicitly remanufacturing and reuse. Under the JRC methodology’s value-versus-effort lens, in-use data looks like a strong candidate for the “strongly recommended” tier today, and possibly something more central over time. The DPP is already meant to support reuse, remanufacturing and recycling. Operational data is what makes those decisions defensible, and it opens a buyer persona that barely existed five years ago: remanufacturing operators and secondary-market platforms, sourcing from the installed base rather than from the factory.

How this applies in practice

It is most concrete for non-powered industrial equipment: machines, gensets, compressors and similar. Our trackers run for years on those assets without recharging, capturing utilisation, location, shock and environmental exposure, and feeding all of it into a platform that already exposes structured APIs. Aligning those exports to the emerging DPP data formats is on our roadmap, so a manufacturer could ingest the data directly into their digital product record once the format settles.

A note on returnable transport items: pallets, roll cages and similar reusable packaging are a natural fit for “prove rotation rate and dwell time” thinking. They are not in scope for ESPR, though; they are covered by the Packaging and Packaging Waste Regulation (PPWR). The principle is similar, the regulation is different. Learn more about it in this article.

It is too early to set out a checklist of actions. We do not know enough yet about the timing or shape of each delegated act to tell manufacturers what they should do. What we can offer is a sense of where the regulation is pointing.

The point of the DPP is not to add paperwork. It is to support better eco-design: products that last longer, are easier to repair, are reused more times, and end up recycled rather than discarded. For industrial assets, this translates into more rotations, fewer abandoned items in yards, longer service lives, and a working market for second-life equipment. If in-use data helps any of that happen, it is doing its job.

The DPP could change the economics of in-use data. Until now, capturing utilisation and condition data on industrial assets has been a competitive choice. Under ESPR, for an expanding list of product categories, it could become a regulated input as well. The details are still in motion, which is why we are publishing this as a perspective rather than a forecast, and why we are paying close attention to the standardisation work coming out of CEN, CENELEC and ETSI.

If you are scoping how in-use data could fit into your own DPP thinking, we would be happy to compare notes.