Which identifier schemes are permitted, and what is verified

The Ecodesign for Sustainable Products Regulation (ESPR) names one set of identifier standards, and that set is the ISO/IEC 15459 series. It names no vendor scheme.

Nobody on this site knows how many product identifier schemes the European standard on unique identifiers permits. That standard is sold, not published, and nobody here has bought a copy.

Here is what happens if you ignore that. A supplier tells you that European law permits a fixed number of schemes, and that your product number is not one of them. You then pay for a new identity system for your merino jumpers. This site searched for the source of that number, and found only commentary, so no reader can check it.

The regulation names the ISO/IEC 15459 series

ESPR is Regulation (EU) 2024/1781. It is the European law that creates the digital product passport. Annex III, second paragraph, reads:

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.

Read the words "where relevant for the products concerned". The requirement is not absolute for every product.

Annex III(c) names the Global Trade Item Number (GTIN) under ISO/IEC 15459-6. A GTIN is the number behind the retail barcode on a merino jumper. See what a GTIN is and what a product identifier is.

The regulation names no vendor scheme

A search of the full regulation returns no hit for any of these terms:

• GS1
• Digital Link
• IEC 61406
• digital object identifier, or DOI
• decentralised identifier

The search covered the recitals, the articles and every annex. It also returns no hit for ISO/IEC 18004, which is the QR code standard.

So a supplier who says that European law requires one particular scheme is wrong about the regulation. Ask that supplier to name the article. See GS1 Digital Link for what that scheme is, and what it is not.

Article 10(1)(c) makes the ISO/IEC rule an interim rule

Article 10(1)(c) allows those standards, "or equivalent European or international standards until the references of harmonised standards are published".

The European Commission cited six passport standards in Commission Implementing Decision (EU) 2026/1736. That Decision entered into force on 15 July 2026. You can read it in the Official Journal.

What that changes in practice depends on the text of EN 18219, the standard for unique identifiers. This site has not read it. See EN 18219.

A citation does not make a standard mandatory. It gives a product built to the standard a presumption of conformity. That presumption has no practical effect for a product group until a delegated act requires a passport for that group.

The count of permitted schemes comes from commentary

Many pages state that EN 18219 permits a fixed number of product identifier schemes, and they name GS1 Digital Link among them.

This site searched the commentary that carries the claim. None of it quotes the standard itself.

The reason is money. Each standard in this set costs between 190 and 370 euros on the distributor listings, and nobody here has paid. There is no cheaper local copy either, because Standards New Zealand has adopted none of these standards. See why the texts are paywalled.

A callout number on a slide is not a count

The one piece of evidence cited for the number does not support it.

A slide from CEN and CENELEC, the two European standards bodies, shows a diagram of identification schemes for products. Numbers appear beside the items in that picture. Those are diagram callouts. A callout number labels a part of a drawing, and it states no total.

This site cannot say where the count first came from. So when a supplier quotes a number of permitted schemes, ask which clause of the purchased standard states it. Do not choose an identifier on the answer alone, because your EU customer decides what it accepts.

The same gap covers the economic operator identifier

A product number is not the only identifier under discussion. The same commentary describes schemes for the economic operator, which is the company that puts the product on the European market.

That commentary gives a count for the operator schemes as well, and it names two of them. The paywall applies to this part of the standard too. Do not treat a named pair as the complete list. See economic operator identifiers and why an NZBN is not enough.

The ISO/IEC series is verified, and the scheme count is not

The battery passport is a separate question

One passport duty, the battery passport, comes from a different regulation, and it applies from 18 February 2027.

Warning: do not read the phrase "large batteries" and decide that you are outside the scope. An LMT battery is an e-bike battery or an e-scooter battery. It carries no size threshold.

The Commission web page on digital product passports writes "certain types of batteries, including". Do not read that open list as an exemption either.

Each battery in those three categories carries its own passport. Each passport needs its own unique identifier, and Article 77(3) states that requirement.

This site checked one further claim and could not support it. That claim says the battery passport prescribes the ISO/IEC 15459 series. This site does not repeat it. See batteries.

Four questions before you buy an identifier service

Ask these of any supplier who quotes a number of permitted schemes.

1. Where does the count come from? Name the document and the page.
2. Which article of the regulation requires my scheme? Give the number.
3. Has anybody in your company read the purchased text of EN 18219?
4. Which delegated act covers my product group today?

The answer to the fourth question is none, under the ecodesign regulation. The Commission had adopted no such act on 14 August 2026. See what a delegated act is.

Nothing forces you to change your product number this year

Warning: a scheme change is expensive and hard to reverse. Your customers hold your numbers in their systems. Your numbers are also on your labels and in your data carriers. Change them for a stated requirement, and not for a claim you cannot check.

No ecodesign passport rule binds any product group today. So no European rule tells you which identifier to hold for a jumper, a chair or a tyre.

If you already hold GTINs, you hold a number that the regulation names in Annex III(c). A new scheme bought on an unverified count is a worse position.

This page changes when somebody reads the standard

This gap stays open until somebody buys the text of EN 18219 and reads it. If that happens, this site will publish the count and the named schemes. It will also give the clause number that states them.

Until then it publishes neither. If you export from New Zealand, read what this means for New Zealand exporters next.