The standards
prEN 18239 is a draft standard, and it binds nobody
The draft covers access rights for a passport. The Official Journal does not cite it, so it gives you no presumption of conformity.
prEN 18239 is a draft European standard on who may read a digital product passport, and its formal vote closed on 16 July 2026. It is not published, the Official Journal does not cite it, and it requires nothing of anybody today.
A draft can still cost you money. You may build an access control model on wording that can change before publication. You may also accept a supplier claim that nobody can check, because the document is not public.
The letters pr at the front mean draft
CEN and CENELEC are the European standards bodies. They write digital product passport standards in a joint committee, CEN/CLC/JTC 24.
A finished standard from that committee carries the letters EN and a number. A document that is still inside the approval process carries the letters pr in front.
Compare the numbers. The six standards the European Commission cited carry no pr:
- EN 18216
- EN 18219
- EN 18220
- EN 18221
- EN 18222
- EN 18223
The numbers have a gap. There is no EN 18217 and no EN 18218, so do not write the six as a range. See which standards apply for the official titles.
prEN 18239 keeps its pr because it is still inside the approval process.
The status: the vote closed, and the document is not published
The table gives every status this site can confirm.
| Item | Status |
|---|---|
| Number | prEN 18239, draft |
| Committee | CEN/CLC/JTC 24, secretariat at DIN |
| Mandate | Standardisation Request M/604 |
| Formal vote | Closed on 16 July 2026 |
| Publication | None. CEN and CENELEC still show it as under approval. |
| Citation in the Official Journal | None |
A closed vote is not a publication. When this site last checked, CEN and CENELEC still listed the document as under approval.
The other draft from the same committee is prEN 18246, on data authentication. It is not published either, and the Official Journal does not cite it.
Not cited means no presumption of conformity
The European Commission cited six standards in Commission Implementing Decision (EU) 2026/1736. That Decision is in force, and the text sits in the Official Journal.
prEN 18239 is not one of the six. So it gives no presumption of conformity, and a product built to it gets no legal benefit.
Read the limit of the presumption carefully, because it is narrow even for the six. The ecodesign regulation sets that limit. It is the Ecodesign for Sustainable Products Regulation (ESPR), Regulation (EU) 2024/1781.
| Item | Where it comes from |
|---|---|
| The presumption of conformity | Article 41(2) of the ecodesign regulation |
| The requirements the presumption covers | Articles 10 and 11 of the ecodesign regulation |
The presumption covers how a passport is built. It does not decide if your product needs one. See the Decision.
What the draft covers is reported, not confirmed
Commentary describes prEN 18239 as access rights, information security and confidentiality. It says the draft separates open data from controlled data.
Treat that description as reported. Nobody here has read the document, because it is not published.
The same caution applies to the six published standards. Each text costs between 190 and 370 euros on the distributor listings, and this site has bought none of them. See why the texts are paywalled.
Access rights for batteries come from law, not from a standard
The subject matters even in draft, because one European law already sets access rights, and it names the readers itself.
The battery regulation is Regulation (EU) 2023/1542, and it is in force. Its Article 77(2) sets three tiers of reader. Each tier reads a different part of Annex XIII.
| Tier | Who reads it | Annex XIII |
|---|---|---|
| (a) | The general public | Point 1 |
| (b) | Notified bodies, market surveillance authorities and the Commission | Points 2 and 3 |
| (c) | Any person with a legitimate interest | Points 2 and 4 |
The three tiers are not nested, so a bigger tier does not contain a smaller one. Tier (b) and tier (c) both read point 2. Each of those two tiers then reads a point that the other tier cannot read.
The battery passport duty starts on 18 February 2027. It covers exactly three categories of battery:
- 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
An e-bike battery is a light means of transport battery, and that category carries no size threshold. See batteries and who can see what.
So if you export e-bike batteries, you have a real access model to build.
No implementing act says who has a legitimate interest
Article 77(9) of the battery regulation required the European Commission to adopt implementing acts by 18 August 2026. Those acts must specify who counts as a person with a legitimate interest. They must also specify what that person may download, share, publish and re-use.
This site searched the Official Journal, the Commission comitology register and the Commission planning register on 15 August 2026. It found no adopted act, and no draft act before the committee that must vote on one.
Warning: confirm the position yourself before you build access control for tier (c).
An implementing act is law. A draft standard is not, and it cannot say who counts as a person with a legitimate interest. See public data versus legitimate interest.
Do not buy a system on a claim of conformance with prEN 18239
Warning: do not buy a system because the seller claims conformance with prEN 18239. The document is not public, so the claim has no evidence you can read.
- Ask a supplier which published standard the product implements, by number.
- Ask the supplier to show the clause it meets, from the purchased text.
- Tag each data field with the group of readers that may see it.
- Write the access duties into your supply agreement with your EU importer.
- Check if the Article 77(9) implementing acts exist, before you build.
- Monitor the Official Journal for a citation. A citation changes the status.
Step three keeps its value whatever the draft says, because the battery law already sets the tiers of reader. See agreeing data duties with your EU importer, and what this means for New Zealand exporters for the wider position.