The standards
EN 18219, the standard for unique identifiers
EN 18219 stays voluntary, and the ESPR itself names the ISO/IEC 15459 series and no vendor scheme. No law makes you buy an identifier service.
EN 18219:2026 is the European standard for the unique identifiers in a digital product passport. The European Commission cited it in July 2026. The standard stays voluntary, and it does not decide if your product needs a passport.
A supplier may tell you that European law requires the GS1 Digital Link scheme in your QR code. The regulation names no such scheme. If you accept the claim, you buy a service for a reason that does not exist. You also repeat a rule that your European customer cannot find.
The official title comes from the Decision, and not from a vendor page
| Item | Detail |
|---|---|
| Number and title | EN 18219:2026, Digital product passport - Unique identifiers |
| Publication | Late May 2026. The British Standards Institution dates it 28 May 2026. |
| Citation | Commission Implementing Decision (EU) 2026/1736, in force since 15 July 2026 |
| Author | The CEN and CENELEC committee CEN/CLC/JTC 24, under Standardisation Request M/604 |
The title above is the official title, and it comes from the Decision. You can read that text in the Official Journal.
The Commission cited six passport standards, and EN 18219 is one of them. See which standards apply for the full set, and CEN/CLC/JTC 24 for the committee that wrote them.
Some sources give EN 18219 the wrong title
Warning: check a title against the Decision before you order a document.
Some secondary sources interchange the titles of EN 18216 and EN 18219. They give the identifiers title to EN 18216, and the data exchange title to EN 18219. Each title belongs to the other standard.
Two numbers in this range do not exist. There is no EN 18217 and no EN 18218 in the passport set. Never write the set as a range, because a range names two documents that do not exist. Name each standard on its own, and the table on the six standards gives all six with their titles.
The Ecodesign regulation names the ISO/IEC 15459 series
The Ecodesign for Sustainable Products Regulation (ESPR) is Regulation (EU) 2024/1781. Annex III, second paragraph, reads:
The data carrier, the unique product identifier ... shall, where relevant for the products concerned, comply with standards ISO/IEC 15459-1:2014, ISO/IEC 15459-2:2015, ISO/IEC 15459-3:2014, ISO/IEC 15459-4:2014, ISO/IEC 15459-5:2014 and ISO/IEC 15459-6:2014.
Read the words "where relevant for the products concerned". The requirement is not absolute. A delegated act for each product group sets the passport requirements for that group.
The same paragraph covers the data carrier as well as the identifier. A data carrier holds the identifier, and a QR code is one data carrier. The data carrier has its own standard, EN 18220.
Annex III(c) names the Global Trade Item Number (GTIN) under ISO/IEC 15459-6. A GTIN is the number behind the retail barcode on a merino jumper. See what a GTIN is and product identifiers.
Article 10(1)(c) makes that rule interim
Article 10(1)(c) allows those standards, "or equivalent European or international standards until the references of harmonised standards are published".
So the ISO/IEC 15459 rule is an interim rule. It runs until the references of harmonised standards for the passport identifier appear. EN 18219 is the harmonised standard for the identifier. The Commission published its reference in July 2026.
This site does not state what that changes in practice, because it has not read EN 18219. The section below explains the limit.
ESPR names no vendor identifier scheme
A search of the full regulation returns zero hits for each of these terms:
- GS1
- Digital Link
- IEC 61406
- digital object identifier (DOI)
The search covered the recitals, the 79 articles and every annex. It returns no hit for ISO/IEC 18004, the QR code standard, either.
If a supplier tells you that ESPR requires a QR code to carry a GS1 Digital Link address, the regulation refutes that claim. Ask that supplier to name the article.
That does not make GS1 Digital Link a bad choice. It makes it a choice, and not a legal command. See GS1 Digital Link.
Citation gives a presumption of conformity, not a duty
EN 18219 stays voluntary. Citation in the Official Journal gives a product built to the standard a presumption of conformity. You may meet the legal requirement another way, and then show your own evidence.
| Item | Article of the ESPR |
|---|---|
| The presumption of conformity comes from | Article 41(2) |
| The presumption covers the requirements in | Articles 10 and 11 |
| The Decision does not mention | Article 9 |
Article 9 makes a passport a condition of market access. A harmonised standard never decides if your product needs a passport.
This site does not publish the number of permitted schemes
Nobody here has bought the text of EN 18219. One standard in this set costs between 190 and 370 euros on the distributor listings.
Many pages state that EN 18219 permits a fixed number of product identifier schemes, and they name one scheme among them. This site searched the commentary that carries the count, and none of it quotes the standard.
So this site publishes no count. It also states nothing about which operator identifier schemes the standard permits. Identifier schemes: what is verified lists what this site checked, and what it could not check. The page on why the texts are paywalled gives the reason for that limit.
No ESPR duty applies today, and one battery duty starts in 2027
No ESPR passport duty binds any product group today. The duty starts with a delegated act for each product group. The Commission had adopted no such act on 14 August 2026.
One passport duty is real, and it comes from a different law. The battery regulation is Regulation (EU) 2023/1542. From 18 February 2027 three categories of battery need a passport:
- 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 77(3) requires a unique identifier for each battery. So a battery passport names one item, and not a model. See batteries.
Ask for the article before you buy an identifier service
- Ask a supplier which of the six standards its product implements, by number.
- Ask a supplier who cites a legal requirement for a scheme to name the article.
- Do not buy a standard because somebody says the law forces you to hold it.
- Check first if a delegated act covers your product group.
Your European importer usually holds the battery passport duty
The operator that places the battery on the European market holds that duty. If your company has no European establishment, that operator is your European importer. Regulation (EU) 2023/1542, Article 77(4), states it.
For an ESPR passport the answer is less settled. A white paper from the PARSEC, CIRPASS-2 and BORDERLINK projects says a non-EU manufacturer stays a duty-holder, whatever its establishment. That paper is not the legal text.
You send your identifiers with your data in either case. Agree with your importer who supplies each number. See what a non-EU exporter must supply.