How it works
What an Asset Administration Shell is, and what it does not do
An Asset Administration Shell is a data pattern for describing an asset. It is not a passport, and no verified EU instrument requires it.
An Asset Administration Shell comes from industry practice: it describes one physical asset in structured parts, called submodels. A digital product passport is a duty in European law to make certain product data available to certain readers.
The two are different things. No verified European instrument requires the pattern for that duty. Only your customer can require it, in a contract.
A supplier can tell you that its system is built on the Asset Administration Shell, and that sentence answers no legal requirement. You can pay for the pattern and still hold nothing your European customer can use. See what is not a passport.
The shell is an engineering pattern, and the passport is a legal duty
The Asset Administration Shell comes from industry practice. It answers an engineering problem. One company's software must describe a machine, and another company's software must read that description without help from a person.
The passport comes from European law. It answers a different problem. A regulator decides which data must exist for a product, and which reader may see each part of it.
| Item | Asset Administration Shell | Digital product passport |
|---|---|---|
| What it is | A pattern for describing an asset as data | A duty in European law |
| Where it comes from | Industry practice | Regulation (EU) 2024/1781 and Regulation (EU) 2023/1542 |
| What it decides | The shape of the data | Which data must exist, and who may read it |
| Who can require it | Your customer, in a contract | European law, once a rule covers your product group |
Read the table across one row at a time. A company can meet the duty with the pattern. The pattern alone meets no legal requirement.
Submodels split the description into parts, one part for each aspect
Warning: this site holds no specification text for the Asset Administration Shell. So this page names no submodel, no version and no scope. The last section says what else is missing.
A shell holds submodels. Each submodel covers one aspect of the asset, such as its identification or its documentation. A pump on a factory line can carry one submodel for its nameplate data and another for its manuals.
That arrangement is useful, and it is the reason people connect the pattern to the passport. A passport also splits its content by subject and by reader.
The ecodesign regulation names no data architecture
The Ecodesign for Sustainable Products Regulation (ESPR) is Regulation (EU) 2024/1781. It has been in force since 18 July 2024.
Article 9 makes a passport a condition of market access for a covered product. ESPR creates no passport duty for any product group until the European Commission adopts a delegated act for that group. It has adopted none, as at 14 August 2026. See what a delegated act is.
What ESPR does name is a standard family for the identifier and the data carrier. Annex III names the ISO/IEC 15459 series. It names parts 1 to 6. Article 10(1)(c) makes that an interim rule, until the Commission publishes the references of harmonised standards.
Warning: the search below tested only the four names it lists. It did not test the words Asset Administration Shell, so this page claims no result for them. See which identifier schemes are verified.
A search of the full regulation returns no hit for GS1, for Digital Link, for IEC 61406 or for the digital object identifier (DOI).
The battery law requires a result, not a method
Regulation (EU) 2023/1542, the battery regulation, is in force. It carries the first binding passport duty in European law. That duty starts on 18 February 2027, and it covers three categories:
- each light means of transport (LMT) battery, such as an e-bike battery
- each industrial battery with a capacity greater than 2 kilowatt hours
- each electric vehicle battery
Article 78 sets the technical requirements for that passport. Point (a) requires full interoperability. Interoperability is the result the article asks for. The verified text this site holds names no architecture that delivers it. See batteries and EN 18223, system interoperability.
| The rule | Where it sits | Status |
|---|---|---|
| The passport as a condition of market access | ESPR Article 9 | In force. No delegated act adopted. |
| The identifier and carrier standards | ESPR Annex III, ISO/IEC 15459 series | In force. Interim under Article 10(1)(c). |
| Full interoperability for a battery passport | Regulation (EU) 2023/1542, Article 78(a) | In force. The duty applies from 18 February 2027. |
| The six cited standards | Implementing Decision (EU) 2026/1736 | In force since 15 July 2026. The standards stay voluntary. |
The two standards that could name an architecture are unread here
The Commission cited six European standards in Implementing Decision (EU) 2026/1736:
- EN 18216, data exchange protocols
- EN 18219, unique identifiers
- EN 18220, data carriers
- EN 18221, data storage, archiving, and persistence
- EN 18222, application programming interfaces for product passport lifecycle management and searchability
- EN 18223, system interoperability
Two numbers are missing. There is no EN 18217 and no EN 18218. A supplier who writes the set as a range names two documents that do not exist.
Two of the six cover subjects where a data architecture could appear. They are EN 18216 and EN 18223.
Distributors list one EN text at 190 to 370 EUR, and this site has bought none of them. So this site states no scope for EN 18216 or EN 18223. It does not know if either standard names the Asset Administration Shell. See why the texts are paywalled.
Citation does not make a standard mandatory in any case. A product built to a cited standard gets a presumption of conformity, and each standard stays voluntary. See the six standards.
An existing shell gives you the content, and none of the compliance
Take a manufacturer that already keeps its equipment data in this form. That company saves work on the content, because the data is already structured, already named and already machine-readable.
It saves no work on the compliance. The duty attaches to the operator that places the product on the European market. If you have no establishment in the European Union, that is your European importer. See who the economic operator is and what a non-EU exporter must supply.
Ask a supplier which requirement the implementation meets, by number
Warning: do not accept a technology name in place of a requirement.
- Ask which regulation and which article the implementation answers.
- Ask which of the six cited standards it implements, by number.
- Ask if the answer is a legal requirement or a customer requirement.
- Ask for a full export of your data, in a documented format.
- Ask your European customer which format its own system reads.
The five questions cost only time. A supplier who cannot answer the first three is selling a pattern, not compliance.
What this site does not know about the Asset Administration Shell
This site states what it does not know. Do not assume more than it says.
- This site holds no specification text for the pattern, so it states no scope.
- This site does not know if any cited European standard names it.
- The one mention in this project's working notes came from practitioner commentary that nobody could open. This site does not cite it.
That last rule is general. Commentary never supports a legal claim here, and an address that nobody has opened never goes on a page. See the source register.
If you export from New Zealand, read what this means for New Zealand exporters first. No passport duty binds a product today, and the first one covers three categories of battery.