What applies – and why this product group is prioritised
For manufacturers of machinery, mobile equipment, attachments and industrial components, assuming digital product passports are years away is a costly mistake. Two major EU deadlines converge in early 2027: on 20 January 2027 the new Machinery Regulation (EU) 2023/1230 takes effect (enabling digital instructions for use and digital EU Declarations of Conformity linked to the machine), and on 18 February 2027 the digital battery passport becomes mandatory for all electric machines powered by industrial batteries above 2 kWh.
At the same time, machines are built from the exact materials and sub-systems prioritised under ESPR – iron, steel and aluminium, electronics, electric motors, tyres and hydraulics. By consolidating machine master data and supplier certificates into a digital product passport per serial number, you solve regulatory compliance while creating a direct digital aftermarket channel for service and spare parts.
Product data and documentation to map now
A digital product passport relies on verifiable master data and traceable supplier evidence. For this product group, you should structure data across four core domains:
Serial number, DoC and technical file
- Unique machine identity (model, serial number/PIN, manufacturing year and configuration)
- EU Declaration of Conformity (DoC) or Declaration of Incorporation under (EU) 2023/1230
- Applied harmonised standards, safety categories and type-examination certificates
- Version-controlled digital operator manuals and safety instructions in required market languages
Purchased components and child passports
- Multi-level As-Built BOM covering chassis, drivetrain, control system, hydraulics and electrics
- Links to embedded child passports (e.g. battery passport > 2 kWh from Feb 2027)
- Material provenance and carbon data for heavy structural steel, castings and aluminium parts
- Supplier traceability for safety-critical and regulated components
REACH, RoHS and lifecycle footprint
- REACH SVHC declarations (> 0.1% w/w) and SCIP notifications for complex assemblies
- RoHS, EMC and RED compliance for on-board control units and radio/telemetry modules
- Disclosure of hydraulic oils, lubricants, coolants and hazardous substances
- Product Carbon Footprint (PCF) across manufacturing and operational use phases
Spare parts, maintenance, retrofit and dismantling
- Spare parts catalogue, wear parts and exploded views tied to the exact serial number
- Service intervals, maintenance checklists and log of retrofits or software upgrades
- Instructions for remanufacturing, refurbishment and component harvesting
- End-of-life depollution and dismantling guide for batteries, electronics and metal fractions
Typical data challenges – and how to avoid data debt
When machines are configured to order or built in small batches, operator manuals, CE certificates, supplier 3.1 mill certificates, battery data and REACH declarations end up scattered across engineering, purchasing and aftermarket systems. And if you supply sub-assemblies or components to larger OEMs, your customers will soon require structured DPP data from you to compile their own machine passports.
Original Creation connects item and BOM structures from your ERP/PLM with automated supplier data requests. The result is a complete digital product passport per machine serial number or component – ready for January/February 2027 and upcoming ESPR rules. Read more in our guide from ERP and PLM to product passports.
How to get started in 3 practical steps
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1
Audit your 2027 exposure: embedded batteries and digital machine manuals
Identify immediately whether your machines contain batteries > 2 kWh (18 Feb 2027 deadline) and how you plan to deliver digital manuals and DoCs under the Machinery Regulation.
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2
Prioritise your BOM by weight and regulatory risk
Start with the 20% of components that account for 80% of machine weight (steel/castings) and compliance exposure (battery, electronics, hydraulics).
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3
Launch a combined compliance and aftermarket passport per serial number in OC
Place a durable QR data plate on the machine giving customers instant access to the exact DoC, manual, spare parts list and sustainability data.