Repairing, maintaining, tracking: how maintenance fits into the Digital Product Passport

Introduction: The Passport Doesn’t Close at the Point of Sale

For years, a product’s technical specification sheet served as a "snapshot"—describing the item exactly as it left the factory, remaining static thereafter. The Digital Product Passport (DPP), introduced by Regulation (EU) 2024/1781 (ESPR), shifts this perspective: the passport accompanies the product throughout its entire lifecycle. For many product categories, the most significant phase of this lifecycle begins only after the purchase—as the product is used, experiences wear and tear, potentially breaks down, and—ideally—undergoes repair.

Consequently, when designing a DPP, one must address a question that may seem simple but carries profound implications for data architecture: does the product require maintenance or repairs? The answer dictates what information should be included in the passport (such as spare parts, instructions, or disassembly diagrams), whether the passport will need to be updated over time, and who is authorized to input data into it.

In this article, we explore this question, the underlying regulatory framework, and practical guidance for key sectors.

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Why Maintenance Matters for the DPP

The rationale behind the ESPR is straightforward: a product that lasts longer and is easily repaired consumes fewer resources and generates less waste. Among the ecodesign requirements that the European Commission may mandate through delegated acts are, explicitly, durability, reparability, and the availability of spare parts. The passport serves as the tool that makes these attributes verifiable and accessible to those who perform work on the product. In practical terms, the answer to the question regarding maintenance affects three aspects of the project:

1. Informational content — If a product is repairable, its passport must contain data useful for repairs, such as spare part codes, instructions, disassembly and safety information, and contact details for support services.
2. Data dynamism — If maintenance or repair interventions need to be recorded, the passport ceases to be a static document and becomes an evolving log. This leads to the next question in the guide: should the data be static or dynamic?
3. Governance and access — Repairers, refurbishers, and service centers need the ability to read (and sometimes write) data that is not intended for the general public. Consequently, differentiated access levels are required.

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The three possible answers

This question must be addressed for each product category covered by the project, as a single company may manage product lines that differ significantly from one another.

Answer	Meaning	Example
Yes	The product is repaired or maintained throughout its lifespan.	Replacing battery cells; resoling a shoe.
No	The product is not intended for repair or maintenance.	Insulation material installed inside a wall.
Depends on the product	The category includes both repairable and non-repairable items.	A repairable sofa and a one-piece molded chair within the same product line.

Choosing "Depends" is not an easy way out; rather, it indicates that the passport’s data model must be modular, with repair-related fields that can be activated only for the products that require them. This is a design decision that should be made early on, as adding such flexibility at a later stage is significantly more costly. ---

The Regulatory Framework

Regulation (EU) 2024/1781 — ESPR

The ESPR (Ecodesign for Sustainable Products Regulation) serves as the overarching framework from which the Digital Product Passport (DPP) originates. The regulation itself does not impose specific reparability requirements on individual products; rather, this is done through delegated acts for specific product groups, which will also define the information that must be included in the passport.

The first ESPR working plan for 2025–2030, adopted by the Commission on April 16, 2025, identifies steel and aluminum, textiles (particularly clothing), furniture, tires, and mattresses as priorities. In addition to these specific product categories, the plan includes horizontal measures regarding reparability—such as a reparability score—for items like consumer electronics and small household appliances. The adoption dates are indicative and staggered: according to the plan’s summary, they range from 2026 for iron and steel to 2029 for mattresses, with horizontal requirements scheduled for introduction between 2027 and 2029.

What this means for those designing a DPP: Even if the delegated act for a specific product category has not yet been adopted, the direction is clear. Structuring data on durability, spare parts, and repair now will prevent the need for rework once the regulations come into effect.

Directive (EU) 2024/1799 — Right to Repair

While the ESPR (Ecodesign for Sustainable Products Regulation) focuses on product design, the Right to Repair Directive addresses the relationship between the manufacturer and the consumer after the sale. For certain categories of goods—specifically those already subject to EU-level reparability requirements, such as various household appliances and electronic devices—it mandates that manufacturers provide repairs even beyond the legal warranty period, at reasonable prices, and prohibits practices that hinder repair.

Key dates:

• The Directive has been in force since July 30, 2024; the deadline for national transposition and implementation was July 31, 2026.
• The new rules regarding the legal warranty apply to sales contracts concluded after July 31, 2026.
• The European online platform for repair—designed to connect consumers with repairers and sellers of refurbished goods—must be operational by July 31, 2027.
• In Italy, the transposition occurred after the deadline: according to press reports, Legislative Decree 176/2026 was published on October 7 and has been in effect since October 22, 2026.
• The list of covered products is dynamic; a 2026 delegated directive has already added local space heaters.

What this means for those designing the DPP (Digital Product Passport): For products covered by the Directive, information regarding spare parts, repair services, and access conditions becomes a concrete commercial obligation. The passport serves as the natural medium for making this information available in a structured and consistent manner. ### Regulation (EU) 2023/1542 — Batteries

The battery passport represents the most advanced use case, setting a precedent for other sectors. From February 18, 2027, every electric vehicle (EV) battery, light means of transport (LMT) battery, and industrial battery with a capacity exceeding 2 kWh placed on the market must have its own passport (Article 77). As this is a regulation, it applies directly across all Member States, requiring no national transposition.

In this context, maintenance is not optional: Article 14 mandates that information regarding the State of Health (SoH) and expected lifespan must be available and kept up to date throughout the battery's lifecycle. Annex XIII categorizes data into three tiers: public data; data accessible to parties with a legitimate interest—such as repairers, refurbishers, and end-of-life operators; and data restricted to authorities.

Implications for those designing the Digital Product Passport (DPP): By definition, the battery passport is dynamic and multi-stakeholder. Entities responsible for fleet management or maintenance hold certain data that must be updated (e.g., State of Health, service interventions) and must therefore have the ability to write to the passport, even without being its primary owner.

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Sector-Specific Guidance

EV, LMT, and Industrial Batteries

The short answer is yes. The State of Health and expected lifespan must be updated over time. From the outset, you must plan for:

• who will collect usage data (e.g., via the Battery Management System (BMS), telematics, or workshops);
• the frequency of these updates;
• how service interventions—such as the replacement of modules or cells—are recorded;
• how the passport remains associated with the battery throughout its "second life" (for instance, if an EV battery pack is repurposed for stationary energy storage). ### Electronics Typical answer: Yes. Repairability and spare parts are among the expected requirements, and the "right to repair" directive also applies to several categories. For some products, specific ecodesign regulations are already in place, mandating the availability of spare parts and information for repairers (this is the case for smartphones and tablets). It makes sense to include the following in the passport: a list and codes for spare parts, their period of availability, repair instructions or links to technical documentation, and potentially a repairability score.

Commercial vehicle tires

Typical answer: Yes. These are often retreaded, and retreading is, for all intents and purposes, an intervention that extends the product's lifespan. It is worth considering whether to record such interventions in the passport; doing so enhances traceability and the value of the retreaded tire, though it requires the involvement of retreaders within the data supply chain. Furthermore, tires are among the priorities of the ESPR (Ecodesign for Sustainable Products Regulation) work plan.

Textiles and furniture

Typical answer: Depends on the product. High-end items (such as technical outerwear or designer sofas) are frequently repaired, whereas mass-market consumer goods rarely are. Both sectors are priorities under the ESPR plan, with a focus on durability and repairability. The recommendation is to adopt a unified data model that includes optional sections for repair, allowing for the management of a diverse product range without the need for multiple, separate formats.

Materials (steel, aluminum, construction materials)

Typical answer: No. As individual products, a steel coil or an aluminum ingot do not require maintenance. Answer Yes only if the passport concerns components or finished products (for example, an aluminum window frame with replaceable gaskets).

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From "Yes" to data: what to include in the passport

If the answer is "Yes" or "It depends," it is advisable to consider four blocks of information.

1. Static repairability information (defined at the time of production)

• Codes and descriptions of key spare parts
• Minimum period of spare parts availability
• Instructions for routine maintenance and repair, or links to relevant documentation
• Information on disassembly, required tools, and safety measures
• Contact details for customer support and the repair network

2. Status data (updated during use)

• Health status, cycles, operating hours (where applicable)
• Estimated remaining service life

3. Record of interventions

• Date and type of intervention
• Components replaced, with references to spare part codes
• Party that performed the intervention

4. Access rules

• Which data is public, which is restricted to repairers and refurbishers, and which is accessible to authorities
• Who is authorized to edit specific fields, and how changes are authenticated

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Common mistakes to avoid

• Answering "No" for the sake of convenience. Declaring a product non-repairable simply to simplify the passport may conflict with current or future requirements and sends an unattractive message to the market. - Confusing the product with the material. Manufacturers of materials that end up in repairable components must clarify at which level their specific passport applies.
• Designing a static passport for a dynamic product. If interventions need to be recorded, the infrastructure must support tracked, multi-stakeholder updates from the outset.
• Overlooking the after-sales supply chain. Independent repairers, remanufacturers, and refurbishers are key users of the passport; involving them early on prevents data gaps.
• Treating a product category as a monolithic block. When a product range is heterogeneous, the correct answer is "it depends"—and the data model must reflect this.

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Conclusion

The question of maintenance may seem technical, but it strikes at the heart of the ESPR philosophy: ensuring products last longer and making their history transparent. For batteries, the requirement is already set for February 18, 2027; for electronics, the "right to repair" is already a commercial reality; and for textiles, furniture, and tires, delegated acts are on the way.

Providing precise answers—category by category—enables the design of a passport that is not merely compliant, but genuinely useful to those who, over the years, will be tasked with maintaining, repairing, and recirculating the product.