How it works
Structured data, and why no EU law names a format
Structured data gives each value a label a machine can read. No EU text this site has read names a data format for a passport.
Structured data means data written so that a machine reads each value without a person to interpret it. No EU document that this site has read requires a format for a digital product passport. The law that creates the passport names standards for the identifier, and no data format.
A supplier can tell you that EU law requires one format, and sell you a system on that basis. Ask that supplier which article requires it. This site has found no such article.
A person reads a sentence, and a machine needs a label
Take the web page for a merino jumper. The page says the jumper is 80 per cent merino wool. A person reads that and understands it.
A machine sees a sentence. It cannot tell which word is the material and which number is the share.
Structured data fixes that. Each value carries a label that the machine already knows.
| What the page says | What structured data holds |
|---|---|
| 80 per cent merino wool | material: merino wool; share: 80 per cent |
| Made in New Zealand | country of origin: New Zealand |
| Wash at 30 degrees | care temperature: 30 degrees Celsius |
A buyer's purchasing system, a customs system and a recycler's system then read the same value and agree what it means. See how a passport works and why your website cannot be the passport.
JSON-LD is one way to write structured data
JSON-LD stands for JavaScript Object Notation for Linked Data. It writes each value with a label, and it adds a list that points every label at a published definition. Its media type is application/ld+json, which is the name a system uses when it asks for that form.
No document that this site has read makes JSON-LD a legal requirement. A buyer can still ask for it, and that request is a commercial term.
One check matters more than the choice. Each label must point at an address that answers. If a label points at an address which returns an error, the machine finds no definition.
The law names an identifier standard, and no data format
The EU law that creates the passport is the Ecodesign for Sustainable Products Regulation (ESPR), Regulation (EU) 2024/1781. It has been in force since 18 July 2024.
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.
| Point | What ESPR says | Status |
|---|---|---|
| Annex III | The data carrier and the unique product identifier comply with the ISO/IEC 15459 series, parts 1 to 6, where relevant for the product | In force since 18 July 2024 |
| Annex III(c) | It names the Global Trade Item Number (GTIN) under part 6 | In force since 18 July 2024 |
| Article 10(1)(c) | Those standards apply, or equivalent European or international standards, until the Commission publishes the references of harmonised standards | In force since 18 July 2024 |
A case-insensitive search covered the full regulation: the recitals, the 79 articles and every annex. Each of these terms returns zero hits:
- GS1
- Digital Link
- IEC 61406
- digital object identifier (DOI)
- decentralised identifier
- ISO/IEC 18004, which is the QR code standard
So ESPR names a standard series for the identifier and the data carrier. It names no data format, no set of agreed field names and no way of writing the file. See the EU does not require a GS1 Digital Link.
The formats would come from the standards, and the texts are paywalled
The European Commission cited six European standards for the passport in Implementing Decision (EU) 2026/1736. That Decision has been in force since 15 July 2026, and its text is in the Official Journal.
Two of the six carry a title that names this subject:
- EN 18216, titled "Digital product passport - Data exchange protocols"
- EN 18223, titled "Digital Product Passport - System interoperability"
Warning: a title is not a scope statement. Each text is paywalled on the distributor listings at 190 to 370 EUR, and this site has bought none of them. So this page states no requirement from either document. See EN 18216 and why the texts are paywalled.
The cited set is six separate documents:
| Standard | Official title |
|---|---|
| EN 18216 | Digital product passport - Data exchange protocols |
| EN 18219 | Digital product passport - Unique identifiers |
| EN 18220 | Digital product passport - Data carriers |
| EN 18221 | Digital product passport - Data storage, archiving, and persistence |
| EN 18222 | Digital Product Passport - Application Programming Interfaces (APIs) for product passport lifecycle management and searchability |
| EN 18223 | Digital Product Passport - System interoperability |
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. See the six standards.
Citation would not settle the question in any case. A product built to a cited standard gets a presumption of conformity, and each of the six standards stays voluntary.
| Item | Where it comes from |
|---|---|
| The presumption of conformity | ESPR Article 41(2) |
| The requirements it covers | ESPR Articles 10 and 11 |
So this site does not tell you which format to use
This site has read no free source that carries a format requirement.
One passport duty is in law today, and it comes from the battery regulation, Regulation (EU) 2023/1542. Article 77(1) gives three categories a battery passport from 18 February 2027:
- 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
Article 78(a) of that regulation requires full interoperability. This site has read no format requirement in it. Warning: Article 78 governs the battery passport alone, and it sets no rule for any other product.
For every other product group, no passport duty starts until the Commission adopts a delegated act for that group. It has adopted none, as at 14 August 2026.
Your customer can require a format, and that is a contract
An EU buyer or a retailer can make one format a condition of sale. Neither one needs a law behind the request.
A customer request is one route by which EU rules reach a New Zealand supplier who carries no EU duty. Treat the request as a commercial term, and write it into the supply contract. See agreeing data duties with your EU importer.
The format is the easy part, and the values are the hard part
A format converts. One system reads a file, and it writes the same values out in another form.
A value that nobody recorded does not convert. If no person in your company can say which fibre percentage is current, no format saves you.
Three questions decide if you can answer a data request:
- Where do you keep each fact about the product?
- Who owns that fact, and who may change it?
- Which version is current, and when did it change?
OwlQR, a New Zealand company that publishes this site, builds product record software. Put the three questions above to any supplier before you buy.
The field names are not settled either. An agreed set of names and meanings is a semantic data model. GS1 said in an apparel webinar on 5 May 2026 that it was forming a subgroup. That subgroup will collect the apparel terms, such as abrasion resistance, and the work is unfinished.
The New Zealand government names no format either. Its one report on the subject comes from the Ministry of Foreign Affairs and Trade, in October 2025. That report tells exporters to prepare by "integrating necessary data tracking and reporting systems". It says the work will need investment in computer systems and in data management. It gives no figure. See what New Zealand agencies have said.
Ask which article requires the format, because ESPR names none
- Ask which document requires the format. Get the name of the document.
- Ask which article or clause requires it. Get the quotation.
- Do not accept ESPR as the answer. The text does not carry it.
- Ask which of the six cited standards the system implements, by number.
- Ask for a full export of your data, in a documented format.
- Ask your EU importer which format its own system reads.
A written answer from your buyer is more useful than a claim about the law.
You probably do not hold the passport, but your data must still be current
You probably do not hold the passport. The operator that places the product on the EU market holds that duty, and that is usually your importer.
Your values still have to be structured and current, because the importer cannot supply what you do not send. See what this means for New Zealand exporters.