The Digital Product Passport in the Energy Industry
From compliance issue to asset data layer for energy supply companies
The Digital Product Passport (DPP) is often discussed as a "new obligation". For energy suppliers, it primarily has a strategic dimension: it links product and component data with the asset lifecycle - and therefore with procurement, operation, maintenance, and dismantling. The decisive factor is not so much whether an energy supply company (ESCO) itself "issues product passports", but rather how well it can read DPP data, evaluate it, integrate it into processes, and use it reliably vis-à-vis internal and external stakeholders.
Classification: What Is the Digital Product Passport?
A digital product passport is a structured, machine-readable dataset uniquely assigned to a product or component that contains information on identity, properties, conformity, and life cycle (including repair and end-of-life). The deeper introduction (definition, data categories, typical content) is already well described here.
For energy supply companies, the digital product passport is above all an operationally relevant asset and component data layer that links procurement, maintenance, and dismantling with reliable product and verification information - and thus directly influences availability, costs, and compliance. This is relevant because energy supply companies typically:
operate large, long-lived infrastructures (networks, systems, storage),
have high requirements for availability, security, and verification,
They are heavily dependent on suppliers and service networks during operation.
The Digital Product Passport thus becomes the link between the supply chain and operational processes.
Regulatory Framework: Brief Overview (EU) and What This Means for Germany
The legal framework originates from the EU. Three points are crucial for energy supply companies:
Ecodesign for Sustainable Products Regulation (ESPR) as a "parenthesis": Regulation (EU) 2024/1781 (ESPR) creates the framework in which DPP obligations for product groups are specified by downstream legal acts. Our article already provides a practical classification (incl. logic, mechanism of action, delimitation): "New ecodesign regulation in practice."
The new Construction Products Regulation (CPR - Regulation (EU) 2024/3110) will also introduce a digital product passport system for construction products. The CPR has been in force since January 2025 and will apply from January 8, 2026; however, specific DPP obligations will only arise for specific product groups via downstream delegated acts. For energy supply companies, this is particularly relevant for grid-related construction products, as performance and conformity information must be provided in a structured, digital format in the future.
Specific digital product passports are already scheduled in some cases: Particularly tangible is the Battery Passport. The EU Battery Regulation stipulates, among other things, that from February 18, 2027, certain battery categories (including LMT batteries, industrial batteries > 2 kWh, EV batteries) require an electronic data set ("battery passport") and that batteries will be marked with a QR code from this date.
In Germany-specific terms, this means the focus will be less on specific national approaches and more on enforcement, market requirements, and the realities of tendering/procurement. What counts for energy supply companies is therefore: Which product groups affect our asset classes - and which data flows do we need to master?
Implementation Status: What Is Already Visible Today?
Although the Digital Product Passport will be "rolled out" depending on the product group, three developments are already very concrete:
On 16 April 2025, the EU Commission published a Working Plan. April 2025 a Working Plan 2025-2030 (ESPR + Energy Labeling), which prioritizes for which product groups requirements will be developed next.
The battery area runs ahead (Battery Passport/QR code from 18.02.2027 for defined categories).
For energy supply companies, the implementation status is therefore not just "EU is doing something", but: Suppliers are gradually becoming DPP-capable - and tenders, service processes, and audit requirements are following suit.
Benefits from an Energy Supply Company Perspective: From Data Sheet to Lifecycle Decision-Maker
Although the Digital Product Passport will be "rolled out" depending on the product group, three developments are already very concrete:
On 16 April 2025, the EU Commission published a Working Plan. April 2025, a Working Plan 2025-2030 (ESPR + Energy Labelling), which prioritizes the product groups for which requirements will be developed next. The generic benefits of the Digital Product Passport (transparency, compliance, circular economy) are well known. For energy supply companies, it is worth focusing on three management-related benefit axes:
Operational capability & availability: Faster identification, better service access, fewer media breaks during maintenance, replacement, and recall.
Costs & risk in the asset lifecycle: Better decisions on repair vs. Replacement, spare parts strategy, retrofit/Repowering, deconstruction.
Supplier traceability & supplier control: data for audits, ESG argumentation and procurement become more resilient - not because "more data", but because they are standardized and assigned.
This means that the digital product passport is valuable for energy supply companies if it improves process decisions - not if it is only stored as a document attachment.
The battery area runs ahead (Battery Passport/QR code from 18.02.2027 for defined categories).
For energy supply companies, the implementation status is therefore not just "EU is doing something", but: Suppliers are gradually becoming DPP-capable - and tenders, service processes, and audit requirements are following suit.
Digital Product Passport in Energy Supply Company Practice: Same Logic - Two Asset Worlds
At first glance, the Digital Product Passport is a tool for the circular economy. For energy suppliers, it is also an operational data mechanism: it creates a standardized, machine-readable "fact base" for products and components - across manufacturer, service provider, and system boundaries. This is precisely where the benefits arise, where energy supply companies currently have friction losses in their life cycle processes: clear identification and variant control, verification management, service chains, maintenance, as well as decommissioning and recycling.
To make the importance of the Digital Product Passport for energy supply companies tangible, we look at two typical asset worlds below, which together address many of the practical challenges.
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Smart Metering (SMGW/Smart Meter): DPP logic as a scaling factor in rollout and operation
Smart metering is a highly regulated mass device case. Devices have to be operated securely for many years, managed on a stable version, and rolled out and maintained within service provider chains. The practical problems are well known. Certificates and proofs of conformity are distributed, and managing device variants and firmware versions is difficult. Exchange programs require a correspondingly high level of coordination.
Here, a DPP-like approach can improve three things in particular:
device identity & variant control: unique identities, model/series reference, configuration, and version information as standardized key attributes - not as Excel/portal knowledge.
Auditability: Proof of conformity and safety is referenceable and machine-readable (instead of "PDF ping-pong" between manufacturers, metering point operators, and service providers).
Lifecycle transparency for updates/support: Especially due to the CRA classification of SMGW as a critical product, the relevance of clear information on support, updates, and Vulnerability handling - an area where structured product information can be particularly helpful.
The benefit is not that energy supply companies "collect new data", but that the existing verifications and device metadata become accessible in a standardized way - in line with the roles and access rights in the smart metering ecosystem.
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Grid infrastructure (transformers, switchgear, power electronics): DPP logic as a "factual situation" for availability, spare parts and retrofitting
The basic problem is different for transformers, switchgear, and power electronics: not mass device rollout, but long running times, manufacturer heterogeneity, and high criticality. Costs arise more from a lack of technical specifications than from a lack of life-cycle information: Which variant is installed? Which components are compatible? Which retrofit options are permitted? Which verifications apply to precisely this configuration? And what does a clean dismantling and recycling path look like?
A DPP approach can be particularly effective here by:
Configuration and component transparency: Variants, relevant parameters, component lists, and changes (change history) are structured and assignable - important for faults, spare parts, and standardization in operation.
Maintenance, retrofit, replacement: Service and maintenance information, as well as retrofit instructions, help speed decision-making in the asset lifecycle (repair vs. replacement, retrofit vs. new). Replacement, Retrofit vs. New).
Software/firmware reference for power electronics: For inverters and protection/control components, the clear assignment of firmware and software versions, along with support information, is also becoming increasingly important (operational stability, manufacturer changes, security).
Make dismantling/recycling more predictable: Structured end-of-life information reduces uncertainty and improves planning, verification, and residual-value logic.
The same applies here: the digital product passport does not replace established engineering and documentation obligations. It makes the information about the life cycle findable, comparable, and usable across organizational boundaries - and thus reduces operational friction.
The coming years will show which asset classes the Digital Product Passport will next become the standard for. Energy suppliers that create internal structures and interfaces for the Digital Product Passport at an early stage can gain a strategic advantage, while waiting risks being left behind reactively. One thing is clear: the digital product passport will be a central component of the future asset strategy - the only question is how actively you help to shape it in your own company.
Do you have a different opinion on how to use the Digital Product Passport? We want to discuss this with you. Send us a short e-mail. We will arrange an appointment with you as soon as possible.
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