DPP vs. instructions for use

How it applies

• Different law: Instructions for use are part of the essential health and safety requirements of the Machinery Regulation, which allows them in digital form from January 20, 2027, with a paper copy free of charge on request at the time of purchase. The passport follows the ESPR and its delegated acts.
• Different audiences: Instructions address operators and maintenance staff and must be in a language they understand. The passport addresses consumers, repairers, recyclers, partners and authorities, each with their own access rights.
• Shared infrastructure: A data carrier and unique product identifier may serve both, as long as each content keeps its own legal requirements.
• Omnibus: Digital-by-default product information is a theme of the omnibus packages, notably Omnibus IV. Check its current legislative status before relying on it.
• No shortcut: Putting safety instructions into the passport does not fulfill instruction duties, and linking a manual from the passport does not make it a passport.

Compared with the USA, Canada and China

In the USA and Canada, instructions and warnings follow product safety and liability law and sector standards, and paper remains common; China sets instruction requirements through national standards. None of them links instructions to a product passport.