Digital product passport questions and answers

You probably do not need a digital product passport yet, because each product group gets its duty from a separate rule. No passport rule applies to any product today. Three kinds of battery need a passport from 18 February 2027, under a regulation that is in force.

Read this page before you buy anything. The common mistake is to spend money about two years before any rule reaches your product.

No passport rule applies to your product today

An indicative adoption year is not a compliance date. No ESPR passport duty can start before about mid-2028, and no rule is adopted yet.

Do I need a digital product passport?

Probably not yet. A digital product passport is a set of structured data about one product, reached from a code on the product. The Ecodesign for Sustainable Products Regulation (ESPR) creates the passport. It reaches no product group until the European Commission adopts a separate rule for that group. As at 14 August 2026 the Commission has adopted no such rule. See what is a digital product passport.

When does it start?

For batteries, 18 February 2027. The battery regulation is in force, and the passport duty applies from that date. It covers three kinds of battery:

• 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

No other product group has a start date, because no separate rule exists for it yet. See batteries.

Is it law yet?

The framework is law. The ESPR is in force from 18 July 2024. It creates no duty for any named product on its own. The battery regulation is also in force, and its passport duty applies from 18 February 2027. See the legal basis.

When is my sector's deadline?

Later than the published year, because that year is only the adoption year. The published years are the years the Commission expects to adopt each rule. A rule then passes a scrutiny period. Companies then get at least 18 months, and the ESPR permits a shorter time in a justified case. See how to read the timeline.

Food, drink and wine sit outside the regulation

Does it apply to food?

No. ESPR Article 1(2) excludes food and feed from the regulation. The exclusion covers the product, not the company, so the same exporter's woollen goods may still be covered later. See food and feed are excluded.

Does it apply to wine?

No. The ESPR takes its meaning of food from Regulation (EC) No 178/2002, which says food "includes drink". A bottle of Marlborough sauvignon blanc is food, and so is any other drink. See wine, beer and spirits.

Does it apply to my packaging?

A different regulation covers your packaging. The food exclusion does not cover the bottle, the label or the carton, because each one is a separate physical good in European law. The Packaging Regulation (EU) 2025/40 is that rule. It applies from August 2026, with further steps after that. See packaging.

The passport is the data set behind the QR code

What is the difference between a passport and a QR code?

The QR code is the data carrier. The passport is the structured data set that the carrier leads to. Every battery already needs a QR code under Article 13(6) of the battery regulation, and that code leads to other information, not to a passport. See how a passport differs from a barcode.

Do I need GS1?

The ESPR does not name GS1 or GS1 Digital Link. It names the ISO/IEC 15459 series. Annex III names the Global Trade Item Number (GTIN) under part 6 of that series. A GTIN is a GS1 number, so you can keep your existing barcode number. Some suppliers say the law requires a GS1 Digital Link address, and the regulation text does not say that.

Which identifier scheme must I use?

Nobody outside the standards bodies can answer that yet. The ESPR names the ISO/IEC 15459 series as an interim rule. The European standard on unique identifiers, EN 18219, costs money to read, so the schemes it permits are not public. See identifier schemes: what is verified.

Can I use my own website?

Yes, if your site meets the rules that apply to a passport. The European Union does not hold your passport data. ESPR Article 10(c) requires the operator that creates the passport, or a passport service provider, to store it. One rule is hard for a company site: the passport must outlive the company.

Your European importer usually carries the duty

Who is responsible, me or my importer?

Usually the importer. The battery regulation puts the duty on the operator that places the battery on the European market. For a New Zealand manufacturer with no European office, that operator is the European importer. That does not remove your work, because the importer cannot supply data that you do not give them. See what a non-EU exporter must supply.

Do I have to register with the EU?

Not yet. The Commission's passport registry became operational in July 2026. The ESPR requires the operator that places the product on the market to upload identifiers to the registry. No operator must upload yet, because no product rule applies yet. A registration number is not proof of compliance, and the regulation says so. See the EU registry.

What happens if my company closes?

The passport must outlive your company. The battery regulation says the battery passport stays available after the responsible operator "ceases to exist or ceases its activity in the Union". ESPR Article 10(e) covers insolvency. ESPR Article 10(c) permits a passport service provider to store the passport instead of the company. See what happens if the company closes.

No published figure says what a passport costs

What does it cost?

No published figure exists. No passport pilot has published a cost, a time or an error rate, and the Ministry of Foreign Affairs and Trade gives no number either. One price is public: each European standard text costs between 190 and 370 euros on the distributor listings. See what a passport costs.

What this site searched, and what came back, is listed in what this site does not know.

New Zealand has no rule of its own

Does New Zealand have its own version?

No. New Zealand has no digital product passport law and no draft law. Standards New Zealand has not adopted the six European standards. The six are:

There is no EN 18217 and no EN 18218. A source that writes the six as a range names two standards that do not exist. See which standards apply.

What has the New Zealand government said?

Three agencies have published, and none of them gives you a date. The Ministry of Foreign Affairs and Trade wrote market reports in March 2025 and October 2025. The Ministry of Business, Innovation and Employment names passports on its circular economy page, and still calls the European regulation "proposed". Standards New Zealand sells all six European passport standards. See what New Zealand agencies have said and what New Zealand industry has published.

Find out where your product data lives

What should I do first?

Find out where your product data lives, and who owns it. That work is useful even if no rule ever reaches your product. If you sell batteries, start now, because February 2027 is close. If you sell textiles, furniture, steel or electronics, do not buy a passport system this year. Monitor for your own rule instead. See first steps for a New Zealand exporter.

What will reach me before the law does?

A question from your customer. A European buyer can ask you for product data as a condition of sale, with no law behind the request. That request usually arrives well before any deadline. See which products need a passport, and when.