First steps for a New Zealand exporter

Start with one test. Find out if the European Union (EU) law that creates the passport reaches your product at all.

If you export food, drink, feed, medicine, or living plants or animals, it does not reach your product. You can stop at step one.

If you skip this page you can make one of two mistakes. You buy a passport system years before any rule reaches your product. Or you sell an e-bike battery into the EU and miss 18 February 2027, a date that is already law.

Step one. Check the exclusion list, because your product may be excluded

The law is the Ecodesign for Sustainable Products Regulation (ESPR), Regulation (EU) 2024/1781. Its Article 1(2) lists what the regulation does not cover:

• food and feed
• medicinal products and veterinary medicinal products
• living plants, animals and micro-organisms
• products of human origin
• products of plants and animals that relate directly to their future reproduction

Food includes drink. ESPR takes that meaning from the EU food law, Regulation (EC) No 178/2002. That law says food "includes drink, chewing gum and any substance, including water, intentionally incorporated into the food". A carton of Marlborough sauvignon blanc is food, and so is a can of beer.

An exclusion is not a delay. No EU rule gives food or feed a passport duty. See food and feed are excluded and wine, beer and spirits.

Warning: the exclusion covers the product, not the company. If you sell manuka honey and also sell merino jumpers, the jumpers stay in scope.

If every product you export is on that list, go to step six. Then stop.

Step two. Find the status of your sector, because only batteries have a date

As at August 2026 the European Commission has adopted no ESPR rule for any product group. Each group needs its own rule, called a delegated act. So no ESPR passport is mandatory today. One passport duty is already law, and it comes from the battery regulation, Regulation (EU) 2023/1542.

An indicative adoption year is the year the Commission expects to write the rule. It is not your compliance date. A scrutiny period and a transition period follow it, as how to read the timeline sets out.

Article 4(4) sets that transition period at 18 months as the usual minimum. The same article permits an earlier date in a duly justified case.

Warning: some guidance calls this a rule for "large batteries". The light means of transport category carries no size threshold, so a small e-bike battery is covered. The Commission web page on digital product passports writes "certain types of batteries, including", and that list is open.

The battery regulation gives every battery a QR code to other information. That QR code is not a passport. See batteries and which products need a passport.

Step three. Name the operator who places your product on the EU market

Warning: that operator can authorise another operator in writing to act for it. The authorisation does not transfer the responsibility.

That operator carries the legal duty. If your company has no EU office, the operator is usually your EU importer. The battery regulation puts the duty on the operator that places the battery on the market. ESPR gives the registry duty to the operator that places the product on the market.

Write down the name of that company today. If nobody in your business can name it, you cannot answer any other question on this page. See who is the economic operator.

Step four. Ask your European buyer what they need and when, and get it in writing

A European buyer can ask you for product data as a condition of sale, with no law behind the request. If you cannot supply the data, the buyer can refuse the order.

For a battery, the importer must check a fixed package before it places the battery on the EU market:

• the EU declaration of conformity
• the technical documentation
• the conformity assessment, carried out by the manufacturer
• the CE marking on the battery
• the marking and the labelling

Only you can produce those items. See what a non-EU exporter must supply.

Agree in writing who supplies each item, who approves it, and who updates it after a change. See agreeing data duties.

Step five. Find out where your product data lives and who owns it

This step is useful even if no rule reaches your product. Answer five questions about the products you export:

• Does each product have a unique and persistent identifier?
• Is there one current source for specifications, certificates and test results?
• Does each important field have a named owner who can approve a change?
• Do you record certificate expiry dates and supplier changes?
• Can you separate the public information from the confidential information?

A "no" is not a failure, because it shows where the work starts.

You can answer all five questions in a spreadsheet. A system becomes useful later, when one product record must serve many buyers and stay current. OwlQR, a New Zealand company that publishes this site, builds this type of product record.

Step six. Check your packaging rules, because your packaging is not excluded

Packaging is a separate physical good in EU law, and the food exclusion does not cover it.

The Packaging and Packaging Waste Regulation is Regulation (EU) 2025/40. It applies from August 2026, and more steps follow. The start date of its labelling article is not confirmed here. See packaging.

Do not buy a passport system, and do not treat an adoption year as a deadline

Do not buy a passport system for a sector with no adopted rule. The delegated act sets the data fields, and no act exists for your group yet.

Do not treat an indicative adoption year as a deadline. A supplier who sells you a 2027 textile deadline quotes the year the Commission plans to adopt the rule.

Check the law, because the local guidance is out of date

New Zealand government material is limited, and some of it is out of date. One page still calls the European regulation "proposed", two years after it became law.

This site searched for New Zealand material on 16 August 2026, in fifteen separate searches, and read 104 separate pages. The Ministry of Foreign Affairs and Trade wrote the substantial government account, in a market report of October 2025. See what New Zealand agencies have said.

A New Zealand page may have left you a question. Check does this reach my product and how would I build one.

Repeat step two once each quarter. Monitor for the delegated act in your own sector. When the act appears, read the date of application in its text. The New Zealand exporters page answers the wider question.