Digital Product Passport

Reference

Digital product passport glossary

Plain definitions of every term on this site, from adopted to unique product identifier, each one written to be read on its own.

Published . Updated . Checked . Due for review .

Adopted means the European Commission has made a rule. In force means the act is law. Applies is the date your duty starts.

Read the status word first. If you read "adopted" as "applies", you will prepare about two years too early. You may also miss the battery date of 18 February 2027, which is fixed.

Read the status word before you read the date

These four words decide what a legal date means.

  • Adopted. The European Commission has made the rule. Nothing binds you yet.
  • In force. The act is law. It may still create no duty for you.
  • Applies. The duty starts. This is the date you plan against.
  • Indicative. A Commission plan. It can move.

The table below adds three more words. A standard is published. A database is operational. A deadline in the law binds the Commission, not you.

EventDateStatus
Ecodesign regulation adopted13 June 2024adopted
Ecodesign regulation entered into force18 July 2024in force
Six passport standards publishedLate May 2026published
Implementing Decision (EU) 2026/1736 in force15 July 2026in force
Deadline in Article 13(1) for the EU registry19 July 2026deadline
EU registry opened, with a testing environment20 July 2026operational
Battery passport starts to apply18 February 2027applies

The terms, in alphabetical order

Adopted

Adopted means the Commission has formally made a rule. Your duty does not start on that date. The years published for each product group are adoption years, not compliance dates.

Application date

The application date is the date a rule starts to bind you. For a delegated act under the ecodesign regulation it is at least 18 months after entry into force. The law allows an earlier date in duly justified cases, so read the act itself.

Battery passport

The battery passport is an electronic record required by Regulation (EU) 2023/1542. From 18 February 2027 three kinds of battery need one:

  • 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

It is the first passport duty in EU law to bind. See batteries.

CE marking

CE marking is a mark that the manufacturer puts on a product to show that it meets EU requirements. It is separate from the passport. Under the battery regulation an EU importer must check the CE marking. It must do so before it places the battery on the market.

CEN and CENELEC

CEN and CENELEC are two European standards bodies. Together they run the joint technical committee that wrote the passport standards. That committee is JTC 24.

Conformity assessment

Conformity assessment is the process that proves a product meets the legal requirements before sale. Some laws let the manufacturer check its own production. Other laws require a third party, which is a notified body. Under the battery regulation an EU importer must check that the manufacturer carried out the right procedure.

Data carrier

A data carrier is the code on the product that leads to the passport, usually a QR code. The ecodesign regulation requires the carrier to be physically present on the product, its packaging or its documentation. Each delegated act sets the layout and the position of the carrier.

Declaration of conformity

The EU declaration of conformity is the document in which the manufacturer declares that the product meets the requirements. The ecodesign regulation requires the passport to carry it, with the technical documentation and any conformity certificates. Your EU importer will ask you for it.

Delegated act

A delegated act is a rule that the Commission makes under a power in a parent regulation. Under the ecodesign regulation each product group needs its own delegated act before any passport duty exists. As at August 2026 the Commission has adopted none for any group. See what a delegated act is.

Digital product passport

A digital product passport is a structured set of data about one product. A person or a machine reaches it through a data carrier on the product, its packaging or its documentation. Structured means a computer can read the data without a person to interpret it.

Digital product passport service provider

A service provider stores and serves the passport for the economic operator. The ecodesign regulation allows the operator or a service provider to hold the passport. It also requires a back-up copy through a service provider. A delegated act on service providers is planned. A Commission timeline slide and a GS1 webinar give different adoption dates, so this site gives none.

Ecodesign

Ecodesign means rules on how a product is designed, and on the information the maker must give about it. The current EU law is the Ecodesign for Sustainable Products Regulation. It replaced an earlier ecodesign directive, and parts of that directive still apply for transitional purposes.

Economic operator

The economic operator is the party that places the product on the EU market. That party must keep the passport data accurate, complete and up to date. Once a delegated act covers the product, that party also uploads the identifiers to the EU registry. For a New Zealand exporter with no EU establishment, that party is usually the EU importer.

EN standards for digital product passports

The Commission has cited six European standards for the passport. Never write them as a range, because there is no EN 18217 and no EN 18218 in the set.

StandardSubject
EN 18216Data exchange protocols
EN 18219Unique identifiers
EN 18220Data carriers
EN 18221Data storage, archiving, and persistence
EN 18222Application programming interfaces for product passport lifecycle management and searchability
EN 18223System interoperability

The subjects above come from the official titles. The full texts are behind a paywall, so this site does not state what each standard requires. See the standards.

Entry into force

Entry into force is the date an act becomes law. It is not the date your duties start. The ecodesign regulation entered into force in July 2024, and no product group has a passport duty from it yet.

ESPR

ESPR is the Ecodesign for Sustainable Products Regulation, Regulation (EU) 2024/1781. It is in force, and it sets the general rules for the passport. It creates no passport duty for any single product, because that duty comes from a delegated act. Food, feed and medicinal products are outside it. A drink is food, so wine is outside it too.

EU importer

Under the battery regulation an importer is a person or company established in the Union. That importer places a battery from a third country on the EU market. If you manufacture in New Zealand and have no EU establishment, the EU importer is the responsible operator. It must check your conformity documents before it sells. See importer obligations.

GS1 Digital Link is a way to write a product identifier as a web address. The ecodesign regulation does not name it. A search of the full regulation finds no mention of GS1 or of Digital Link. Treat any claim that the law demands it with care. See GS1 Digital Link.

GTIN

GTIN is the global trade item number, the number behind a retail barcode. The ecodesign regulation names the GTIN in Annex III, under ISO/IEC 15459-6. A GTIN identifies the product. The passport also needs an operator identifier and a facility identifier.

Harmonised standard

A harmonised standard is a European standard that the Commission cites in the Official Journal. Citation does not make the standard mandatory. A product built to a cited standard gets a presumption of conformity with the requirements that the standard covers.

Implementing act

An implementing act is an act the Commission adopts to apply a regulation the same way across the EU. Implementing Decision (EU) 2026/1736 is the act that cited the passport standards. Its legal basis is the European standardisation regulation, not the ecodesign regulation.

In force

In force means the act is law. It does not mean that the act binds you today. The ecodesign regulation is in force and binds no product group, because each group waits for its own delegated act.

ISO/IEC 15459

ISO/IEC 15459 is the identifier standard series that the ecodesign regulation names, in parts 1 to 6. Annex III requires the data carrier and the unique identifiers to comply with those parts, or with equivalent standards. That requirement runs until the references of harmonised standards are published.

JTC 24

JTC 24 is the joint CEN and CENELEC committee for the digital product passport framework and system. Its secretariat is at DIN. It wrote the passport standards under Standardisation Request M/604 and an amendment to that request.

LMT battery

LMT means light means of transport. An LMT battery powers a vehicle such as an e-bike or an e-scooter. Every LMT battery needs a battery passport from 18 February 2027, whatever its size.

Two Commission wordings hide that. A Commission news item of 20 July 2026 uses the phrase "large batteries" for this rule. The Commission web page on digital product passports writes "certain types of batteries, including", and that list is open. If you export an e-bike battery, either wording could make you think that your battery is outside the rule.

Market surveillance

Market surveillance is the work national authorities do to check products that are on the market. The battery passport gives those authorities access to data beyond the public part. Customs is a separate matter. Under the ecodesign regulation customs must receive the registration identifier for a covered product.

Notified body

A notified body is an organisation that carries out a conformity assessment where the law requires a third party. Many products need no notified body, because the manufacturer may check its own production. The battery passport gives notified bodies access to data beyond the public part.

Placing on the market

Placing on the market is the first making available of a product on the Union market. It decides who is responsible, because the duty falls on the operator that does it. Under the ecodesign regulation an operator may place a covered product on the market only if a passport is available.

Presumption of conformity

Presumption of conformity means an authority presumes your product meets a requirement, because you built it to a cited standard. For the passport standards the presumption comes from the ecodesign regulation, and it covers the requirements in Articles 10 and 11. It has no practical effect for your product group until a delegated act requires a passport.

Product group

A product group is the set of products that one delegated act covers, such as iron and steel, or textiles. Your date depends on your product group, not on the ecodesign regulation.

Registry

The registry is the EU digital registry. It stores at least the unique identifiers of covered products. Article 13(1) set a deadline of 19 July 2026. The Commission opened the registry, with a testing environment, one day later. It is a directory, not a data store, so the passport data stays with the economic operator or its service provider.

A registration identifier is not proof of compliance. No operator has a duty to upload data yet, because no delegated act applies. See the EU registry.

Resolver

A resolver is the service that turns the identifier in the code into the passport. One web address can answer a person with a readable page, and a machine with structured data. The ecodesign regulation does not use the word resolver. The EU registry requires the unique product identifier to be a web address that resolves to the passport data. See what a resolver is.

Scrutiny period

The scrutiny period is the time Parliament and Council get to object to a delegated act. Under the ecodesign regulation it is two months, and either institution can extend it by two more months. It sits between adoption and the transition period.

Unique product identifier

A unique product identifier names one model, one batch or one item in the passport system. The data carrier on the product connects to it, and the identifier must stay the same over time. In the EU registry the identifier must be a web address that resolves to where the passport data is held.

If you export from New Zealand, read what this means for New Zealand exporters next.