The European market is about to undergo one of the most significant transformations of the last decades in terms of product information. With the entry into force of Regulation (EU) 2024/1781, known as the Ecodesign for Sustainable Products Regulation (ESPR), the European Union has introduced the Digital Product Passport (DPP): a mandatory digital record that will accompany products throughout their entire lifecycle. For companies operating internationally, this is not just a matter of environmental compliance, it is above all a challenge in multilingual technical documentation.
What is the Digital Product Passport and why it changes everything
The Digital Product Passport is a digital data container that collects standardized and verifiable information about a product: origin and composition of materials, environmental impact, repair instructions, safety data, and end-of-life disposal guidelines. The DPP will be physically accessible via a QR code, an NFC chip, or an RFID tag, compliant with ISO/IEC 15459 standards for global traceability.
The ESPR regulation entered into force on July 18, 2024. The first product category affected is industrial and electric vehicle batteries, with a deadline set for February 18, 2027. Adoption will progressively extend until 2030 to sectors such as textiles, electronics, construction, toys, and many others. In practice, any company selling products on the EU market (regardless of the country in which it is registered) will be required to comply with these requirements.
The core issue: who produces DPP content?
The DPP is not a simple digital label. It contains technical, legal, and environmental information that must be accurate, up to date, and accessible. The regulation requires that data remain available for the entire lifespan of the product plus an additional period of ten years. This means companies must establish solid and long-lasting documentation processes capable of managing updates, versions, and revisions over time.
The challenge becomes more complex when considering the multilingual dimension. The EU market includes 24 official languages and a wide range of local regulations. The information contained in the DPP, from user manuals to safety instructions, from composition data to declarations of conformity, must be understandable to consumers, distributors, regulatory authorities, and end-of-life operators across Europe and potentially beyond its borders.
Specific challenges for multilingual technical documentation
The first challenge is terminological consistency. A DPP may contain hundreds of data fields that must maintain consistent technical terminology across all languages, aligned with industry standards and existing company glossaries. An approximate translation of terms such as “recycled content” or “repairability index” can lead to misunderstandings or disputes during customs checks or market inspections.
The second challenge concerns scalability. Companies with large catalogues, such as electronics manufacturers with thousands of SKUs, must manage huge volumes of technical content to translate and update in parallel. Human translators alone are not enough: it is necessary to integrate CAT tools (Computer-Assisted Translation), translation memories, terminology management systems, and AI-based machine translation solutions to efficiently handle large volumes of text. In these localization workflows, machine translation is used as support to increase productivity and speed up processes, but content must always be reviewed and validated by professional translators. Only human revision ensures technical accuracy, terminological consistency, and regulatory compliance.
The third challenge is data structure. The DPP is not a static PDF document: it is an interoperable system built on open standards, where information must be structured so that different software and platforms can read and share it. This means that translation must also be “structured”: instead of translating free text, specific fields within XML or JSON schemas are localized. This requires localization engineering processes, not just translation, a technical discipline that includes extracting text from structured files (XML, JSON, XLIFF), configuring Translation Management Systems, and automatically validating the output to ensure that the data structure remains intact after translation.
The role of the technical writer in building the DPP
In this context, the technical writer plays a strategic role. The technical writer does not simply produce clear and correct source-language texts but must anticipate translation needs and design content according to structured documentation principles, organizing it in a modular and reusable way. To do this, they may apply standards such as DITA (Darwin Information Typing Architecture), an open-source OASIS XML standard that structures content into independent and reusable modules, or S1000D, an international XML standard originating in aerospace and defence, based on the same principle of independent information components managed in a centralized database. Both frameworks allow information to be classified, versioned, and easily updated, reused, and extracted into different required formats. Well-structured documentation upstream reduces translation costs and turnaround times downstream.
In addition, the technical writer must collaborate with legal and compliance teams to ensure that all mandatory information required by the ESPR regulation and its delegated acts specific to each product category is actually present and correctly formulated. This requires knowledge not only of language but also of the European regulatory framework and its sector specific applications.
From single source of truth to multichannel distribution
One of the key principles of effective DPP documentation management is the concept of a “single source of truth”: a single centralized database from which all language versions and output formats are derived, whether it is the digital passport accessible via QR code, the downloadable datasheet, the user manual, or documentation for regulatory authorities. This approach, already well established in the management of complex industrial documentation, is now becoming essential for those who need to comply with the DPP.
Localization must be integrated into the content lifecycle, not treated as a one-off activity to be carried out once the product is finished. The most advanced companies are already adopting PIM (Product Information Management) platforms capable of managing product data in a structured way and exporting it into the formats required by the future ecosystem of DPP Service Providers—certified entities that will host and ensure access to digital passports.
Opportunities and competitive advantages for early adopters
The regulation is not only a burden, it is also an opportunity. Companies that invest today in structured, multilingual, and DPP-compliant technical documentation gain a competitive advantage both in the European market and globally. The transparency imposed by the DPP builds trust among consumers who are increasingly attentive to sustainability and product authenticity.
According to a study published in Intereconomics in 2025 (Büchel & Neligan, German Economic Institute), the majority of German companies surveyed (over 1,000 firms) were still unaware of DPP requirements or did not consider them relevant to their business. Only 4% had already started preparatory measures. This suggests that early movers will have a significant advantage when regulatory deadlines become operational.
Conclusions: technical documentation as a strategic asset
The Digital Product Passport marks a paradigm shift: technical documentation is no longer a bureaucratic requirement but becomes a strategic asset, a driver of transparency, traceability, and trust. To address this transformation, companies must invest in technical writing, localization, and structured content management capabilities. The multilingual challenge is not a secondary detail—it is the core of the issue, and addressing it with the right tools and methodologies will make the difference between those who comply at the last minute and those who turn the DPP into a competitive advantage.
Further reading
→ Regulation (EU) 2024/1781 – Ecodesign for Sustainable Products Regulation (EUR-Lex official text)
→ European Commission – Digital Product Passport public consultation (April 2025)
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