DPP vs. technical file

DPP vs. technical file

	Digital product passport	Technical file
Legal nature	Data and sustainability regulation (ESPR, Battery Regulation)	Product safety and conformity law (e.g. Machinery Regulation)
Purpose	Product information along the lifecycle and value chain	Evidence that the product meets essential requirements
Audience	Public, repairers, recyclers, business partners, authorities	Market surveillance authorities, notified bodies
Visibility	Partly public	Confidential, provided on request
Content	Materials, substances, repair, recycling, compliance references	Risk assessment, design, test reports, standards applied

How it applies

• No replacement: The passport does not replace safety, quality, conformity or sector-specific systems, and having a passport says nothing about whether a product is safe or conforming.
• Machinery: A passport for machinery or its components would focus on component, repair, material, lifecycle and circularity data; the technical file under the Machinery Regulation keeps the safety evidence.
• MedTech and GMP: Packaging, material, supplier and environmental data may flow into passports, while device and GMP documentation stays in its regulated systems.
• Shared data: Both may draw on the same values, such as materials. Keep one source of truth and reference it from both.
• Confidentiality: Do not publish technical file content in the public passport layer by default; see business confidentiality.

Compared with the USA, Canada and China

In all four jurisdictions, conformity or certification evidence is kept separately from traceability data. The EU is the only one adding a lasting, partly public product-information layer next to it.