Glossary · DPP and technical documentation
DPP vs. technical file
Also known as: digital product passport vs. technical documentation, DPP and technical file
The distinction between the digital product passport and the technical file: the passport is a partly public, horizontal layer of product information required by EU data and sustainability law, while the technical file is the manufacturer's conformity evidence under product safety law, kept for market surveillance authorities. One does not replace the other.
- EU
- DPP
- Technical documentation
In one sentence
The DPP is a partly public product-information layer under sustainability law; the technical file is conformity evidence kept for authorities.
Example
A machine builder's passport lists spare parts, materials and repair information for customers and recyclers, while its technical file under the Machinery Regulation holds the risk assessment, test reports and design calculations for authorities.
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- Confidentiality: Do not publish technical file content in the public passport layer by default; see business confidentiality.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.
Read more on AI TechDoc Press
- Who owns the EU Digital Product Passport?
- Beyond PIM: building the product data bridge between MR and DPP
The in-depth analysis behind this entry, in the AI TechDoc Press newsletter. Subscribe for free