What digital product passports mean for New Zealand exporters

If you export food or drink from New Zealand, the European Union rule on digital product passports does not apply to your product. Article 1(2) of the law excludes food, and the legal meaning of food covers every drink, including wine.

That one fact ends the question for a food or drink exporter. The rest of this document is for the exporters it does not answer. The questions and answers page gives short answers to the common questions.

Two mistakes cost you money. The first is to buy a passport system that no rule requires. The second is to sell an e-bike battery into the European Union and miss 18 February 2027.

Food, feed and drink are outside the ecodesign rule

The Ecodesign for Sustainable Products Regulation is the European law that creates the passport. Its Article 1(2) lists what it does not cover.

The list includes food and feed. It also includes medicinal products, veterinary medicines, living plants and animals.

Wine is on the list, though not by name. The regulation borrows its meaning of food from another European law, which says food "includes drink". A bottle of Marlborough sauvignon blanc is food. So is beer, and so is bottled water.

Two warnings go with that.

The exclusion covers the product, not the company. If you sell honey and also sell woollen blankets, the blankets are still in scope.

Your packaging is a separate product in European law. It has its own rule, the Packaging and Packaging Waste Regulation. Being a food exporter does not exclude your packaging.

Four groups should read on, and only batteries have a date

Four groups of New Zealand exporters should read further.

You sell batteries. This is the only passport requirement with a firm date. From 18 February 2027 three kinds of battery need one. See the section below.

You sell clothing, footwear or textiles. A rule is planned, and no rule exists yet. The projected start for a textile passport is 2029.

You sell furniture, tyres, steel, aluminium or electronics. Rules are planned for each.

You supply a component or a material to somebody else's product. No European law reaches you. Your customer will still ask you for data. That is the most common way this arrives in New Zealand.

Nothing is mandatory yet, except batteries

As at August 2026, no European passport rule applies to any product group under the ecodesign regulation.

The regulation is in force. It has been since July 2024. But it creates no passport duty on its own. Each product group needs its own rule, called a delegated act, before anything binds. The European Commission has not adopted one for any group.

The exception comes from a different law. The battery regulation sets 18 February 2027 for three kinds of battery:

• Every light means of transport battery. That means e-bikes and e-scooters.
• Every industrial battery above 2 kilowatt hours.
• Every electric vehicle battery.

Note the first one. Some guidance calls this a rule for "large batteries". That is wrong and it is dangerous. An e-bike battery is not large, and it is covered.

The Commission web page on digital product passports writes "certain types of batteries, including". That phrase is open. The three categories above are the full list.

Other batteries need a QR code that leads to information. They do not need a passport.

A planned adoption year is not the date a duty reaches you

The European Commission publishes a plan with a year next to each product group.

Most articles you will read quote those years as deadlines.

They are not deadlines. They are the years the Commission expects to make each rule, and compliance comes later.

After a rule is made, two more things occur. The European Parliament and Council get time to object. Then companies usually get 18 months to prepare.

Warning: 18 months is the usual minimum, and it is not a guarantee. Article 4(4) permits an earlier date in a duly justified case. Read the act itself when one arrives for your product.

Add it up for textiles. The Commission plans to adopt in late 2027. Scrutiny takes up to four months. The transition period is usually 18 months. So the projected start for a textile passport is 2029.

The earliest projected start for any ecodesign passport is about the middle of 2028, and that is steel.

A supplier may tell you that you must be ready for textiles by 2027. That supplier is quoting the year the rule gets written.

Your European importer is usually responsible, and it will ask for five things

A New Zealand company usually has no office in Europe. So it is usually not the company that European law holds responsible.

The responsible party is the operator who places the product on the European market. For most New Zealand exporters that is the European importer.

That does not remove your work. The importer cannot supply what you do not give them. Under the battery law, before an importer can sell your product, they must check that you have:

• drawn up the European declaration of conformity
• drawn up the technical documentation
• had the right conformity assessment done
• applied the CE mark
• applied the required marking and labelling

That list is what your importer will ask you for, and what a non-EU exporter must supply sets it out in full. Agree in writing who supplies each item, who approves it, and who updates it when something changes.

Three agencies have published, and none estimates the cost

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.

That report tells exporters to learn the rules and to prepare by setting up data systems. It also says the work will cost money in systems and data management, without saying how much.

The Ministry of Business, Innovation and Employment still describes the European regulation as "proposed" on its website, two years after it became law. The Ministry for Primary Industries wrote to exporters about European packaging rules in April 2026 and did not mention passports.

This site searched 104 New Zealand pages on 16 August 2026. No agency explains how to build or host a passport, and no agency estimates the cost.

Industry bodies do publish. HERA argues for a digital steel passport, and LASRA writes for the leather sector. See what New Zealand industry has published.

Those pages leave questions open, and each one has an answer here. Read when a passport reaches you and what it costs. Then read who carries the duty and will New Zealand make its own rule.

The free trade agreement with Europe does not mention digital product passports at all. A passport rule is a rule about the product, and the agreement gives you no relief from one. See is a passport a trade barrier.

Only a battery exporter should start now

If you sell food or drink, do nothing about the ecodesign passport. Check your packaging obligations instead, because those are separate and they are moving.

If you sell batteries, start now. February 2027 is close, and the rule applies to each individual battery.

If you sell textiles, furniture, tyres, steel, aluminium or electronics, do not buy a passport system this year. Monitor your sector for the rule. Ask your European customer what they will need and when.

If you supply components, ask your customer directly. Your deadline is their deadline, and it will arrive as a purchase condition rather than as a law.

Everybody should do one thing regardless. Find out where you keep your product data, and who owns it. The most common problem is not the passport. It is that nobody in your business can say which version of the specification is current.