EN 18220, the data carrier standard for passports

EN 18220:2026 is the European standard for the data carrier of a digital product passport. The European Commission cited it in the Official Journal in July 2026. A product built to the standard gains a presumption of conformity.

The standard stays voluntary. No European law forces you to build to it, and no ecodesign passport rule reaches any product group today.

A supplier can sell you printers, tags or readers, and can name this standard as the reason. The text is paywalled, so a scope claim is hard to check. Ask the supplier for the clause before you pay.

EN 18220 is one of six standards the Commission cited

The Decision cites six standards, and EN 18220 is one of them. The text sits in the Official Journal.

Never write the six as a range. There is no EN 18217 and no EN 18218. See the six standards for the full list and the official titles.

Two European standards bodies wrote it. They are CEN and CENELEC, working in the joint committee CEN/CLC/JTC 24. The Commission asked for the work in Standardisation Request M/604.

A data carrier is the code a scanner reads

Data carrier is standards language for a simple thing. It is the printed mark or the embedded tag that a scanner reads. Three examples:

• a QR code on the swing tag of a merino jumper
• a Data Matrix code printed on the case of an e-bike battery
• a radio frequency tag sewn into a garment label

The carrier holds an identifier. It does not hold the passport data. The passport is the structured data set that the identifier leads to.

One test separates the two. Scan the code with a phone. What you scanned is the carrier. What came back is the passport.

The page on data carriers covers QR codes, Data Matrix codes and radio tags in full.

The law permits the carrier on the product, its packaging or its documentation

The ecodesign regulation is the Ecodesign for Sustainable Products Regulation (ESPR), Regulation (EU) 2024/1781. Articles 9 to 11 set the carrier rule.

The passport must be reachable through a data carrier that is physically present. The regulation permits three places: the product, its packaging, or its documentation. The carrier must connect to a unique product identifier, and that identifier must persist.

Annex III sets the technical rule for the carrier and the identifier:

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.

Article 10(1)(c) makes that an interim rule. It allows those standards, or equivalent European or international standards, until the Commission publishes the references of harmonised standards.

ESPR also makes you give a copy of the carrier on request. Article 10(3) covers a request from a dealer or from an online marketplace. The responsible operator must give them a digital copy of the data carrier, or of the unique product identifier. The copy is free of charge, and the limit is five working days. That duty starts only when a delegated act covers the product group. See agreeing data duties.

ESPR does not name the QR code standard

The QR code standard is ISO/IEC 18004. A search of the full ecodesign regulation returns no hit for it. The regulation also returns no hit for GS1, for Digital Link, for IEC 61406 or for the digital object identifier (DOI).

So the regulation does not name a specific symbol. It names the ISO/IEC 15459 series. Annex III names the Global Trade Item Number (GTIN) under part 6 of that series.

That matters when a supplier tells you the law requires a GS1 Digital Link address inside your QR code. The regulation carries no such article. Ask the supplier to show you the text. The identifier itself is the subject of EN 18219, unique identifiers.

A QR code on a product is not proof of a passport

The battery regulation shows the difference. That regulation is Regulation (EU) 2023/1542, and it is in force.

Article 13(6) gives all batteries a QR code, under Annex VI Part C. That code leads to other information. It is not a passport.

A separate duty creates the passport. That duty sits in Article 77, and it applies from 18 February 2027. It reaches 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

Warning: a Commission news item of 20 July 2026 calls this a rule for large batteries, and other guidance repeats the phrase. A light means of transport battery carries no size threshold, and it is covered.

The Commission web page on digital product passports writes "certain types of batteries, including". That list is open, and the three categories above are the full list. See batteries.

So a portable battery in a torch gets the QR code and no passport. An e-bike battery gets the QR code and the passport. The carrier looks the same in both cases.

This site has not read EN 18220

Warning: do not accept a statement about the content of EN 18220 unless the person quotes the purchased text.

The full text is paywalled. One standard in this set costs between 190 and 370 EUR. This site has not bought it.

So this site states nothing about which carriers EN 18220 permits, and nothing about what it says on size, placement or print quality.

Scope summaries do circulate. They come from a CEN and CENELEC webinar deck, not from the standard. A slide is not a normative text, and a distributor page that describes a standard is promotional copy. See why the texts are paywalled.

One such summary says that a phone must read a carrier with no app. See what free access does and does not require.

Citation does not make EN 18220 mandatory

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.

The presumption comes from ESPR Article 41(2). It covers the requirements in Articles 10 and 11. It does not decide if your product needs a passport. Article 9 decides that. Article 9 reaches a product group only after a delegated act covers that group. As at August 2026 the Commission has adopted no such act for any product group.

Buy no hardware until the supplier quotes the clause

Warning: do not buy printers, tags or readers because a supplier names EN 18220. The standard is voluntary, and no ecodesign rule requires a carrier for your product today.

1. Find out if a delegated act covers your product group. Today none does.
2. If you sell batteries, check the three covered categories above.
3. Ask the supplier which standard the equipment meets, by number.
4. Ask the supplier to quote the clause, and to name the purchased document.
5. Treat any scope claim about EN 18220 as unverified until you see that quote.

The page on how a passport works sets the carrier in order with the identifier, the resolver and the stored data.