The standards
What EN 18223 covers, and the law it serves
EN 18223:2026 is one of six cited European standards. It covers passport system interoperability, which the EU battery regulation requires.
EN 18223:2026 covers system interoperability for the digital product passport. It is one of the six European standards that the European Commission cited. Its official title is "Digital Product Passport - System interoperability".
Warning: the full text is paywalled, and this site has not read it. The title is the only content of EN 18223 that this site states as fact.
Interoperability means that two systems, built by different companies for different reasons, exchange data, and each one understands what the other sent.
If you buy a passport service that keeps your data in a form only that service reads, you cannot move to another provider. Your European customer cannot pull the data into its own system either.
Interoperability means another company's system reads your data correctly
Take an e-bike battery. A European importer places it on the market, and the importer's service provider holds the passport. Three years later a recycler in Germany reads the record. A market surveillance authority reads the same record from a different system.
Those three systems belong to different organisations. Interoperability is the property that lets them exchange the record and agree what each field means.
A field named "recycled content" must carry the same meaning at both ends. A number with no shared meaning is not data that an importer can use. An agreed set of names and meanings is a semantic data model. See how a passport works for the steps around that exchange.
The battery regulation requires full interoperability
Article 78 of Regulation (EU) 2023/1542, the battery regulation, sets the technical requirements for a battery passport. Point (a) requires full interoperability. Cite it as Article 78(a).
Warning: Article 78 governs the battery passport, and it does not govern the passport for any other product.
| Item | Detail |
|---|---|
| Instrument | Regulation (EU) 2023/1542, in force |
| The requirement | Article 78(a), full interoperability |
| Date the passport duty starts | 18 February 2027 |
The passport duty 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
See batteries for the scope of that duty.
The ecodesign regulation keeps your data out of a central database
The Ecodesign for Sustainable Products Regulation (ESPR) is Regulation (EU) 2024/1781. It entered into force on 18 July 2024, and it is in force today.
Article 10(c) requires the economic operator responsible for the creation of the passport to store it. A digital product passport service provider may store it instead. Recital 41 requires a decentralised data system.
So no single European database holds the passports. A decentralised system without interoperability keeps each record inside one company's software. See what a service provider does.
The public portal has nothing to compare unless the systems agree
ESPR Article 14 requires a publicly accessible web portal. It lets people search and compare passport data.
A comparison needs two records that use the same field with the same meaning. Interoperability is what makes the search and the comparison work. See the ESPR web portal.
Note the status. ESPR sets no passport duty for a product group until a delegated act covers that group. The Commission has adopted no such act, as at August 2026.
A private data format makes it hard to change provider
Warning: this section describes a consequence of the design. No article gives you a right to change your passport provider.
The law leaves the passport data with the operator, or with a service provider that the operator pays. The battery regulation then requires the data to stay available after the responsible operator stops. Article 78(e) reads:
the battery passport shall remain available after the economic operator responsible for the fulfilment of the obligations under Article 77(4) or (7) ceases to exist or ceases its activity in the Union
If your provider holds the only readable copy in a private format, you depend on that provider to meet the duty. Ask about the export before you sign. See what happens if the company closes.
The text is paywalled, and this site has not read it
Warning: do not accept a scope claim about EN 18223 from a supplier. One EN text costs between 190 and 370 EUR. This site has bought none of them.
The scope summaries in circulation come from a CEN and CENELEC webinar deck, not from the standard. That commentary describes EN 18223 as a shared data model, in which each data element points to a machine-readable definition. Treat the description as reported, not as confirmed. See why the texts are paywalled.
This site also does not know if EN 18223 names the Asset Administration Shell. So ask a supplier who claims that link to quote the clause and the page from the purchased text. An answer that cites a webinar deck is commentary, and not the standard itself.
EN 18223 is one of six cited standards, and the set is not a range
The Commission cited the six standards in Implementing Decision (EU) 2026/1736. The Decision is in the Official Journal.
- 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
Count six. 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.
| Step | Date and status |
|---|---|
| The six standards published | Late May 2026. The BSI catalogue gives 28 May 2026. |
| The Decision adopted | 14 July 2026 |
| The Decision published and in force | 15 July 2026, in force |
Citation does not make EN 18223 mandatory
Citation in the Official Journal does not make a standard mandatory. A product built to a cited standard gets a presumption of conformity, and EN 18223 stays voluntary.
The presumption has a limit, and the table below sets it out.
| Item | Where it comes from |
|---|---|
| The presumption of conformity | ESPR Article 41(2) |
| The requirements it covers | ESPR Articles 10 and 11 |
| The article that decides if your product needs a passport | ESPR Article 9, which the Decision does not mention |
Read the last two rows together. The presumption covers how a passport is built, and not if you need one. See the six standards.
ESPR names ISO/IEC 15459, and it names no vendor scheme
Some suppliers sell one identifier scheme as the route to interoperability. Check the legal text before you accept that.
A search of the full ecodesign regulation returns no hit for GS1, for Digital Link, for IEC 61406 or for the digital object identifier (DOI). Annex III names the ISO/IEC 15459 series. It names parts 1 to 6.
Article 10(1)(c) allows those standards, or equivalent European or international standards, until the Commission publishes the references of harmonised standards.
Ask for a full export of your passport data before you sign
Warning: do not accept a demonstration in place of an export. A screen that shows your data does not prove that you can take the data away.
- Ask which of the six cited standards the service implements, by number.
- Ask for a full export of your passport data, in a documented format.
- Ask what the export costs, and how long it takes.
- Ask who holds a readable copy if the provider stops trading.
- Ask your European importer which format its own system reads.
Put question 2 before you sign, and put the answer in the contract. For the wider position, see what this means for New Zealand exporters.