How it works
What a semantic data model is, and why a passport needs one
A semantic data model is an agreed set of names and meanings, so two systems built by different companies mean the same thing.
A semantic data model is an agreed set of names and meanings for the values in a digital product passport. It lets two systems, built by different companies, mean the same thing by the same word.
Warning: no ecodesign passport duty binds any product today. The battery regulation is in force, and its passport duty starts on 18 February 2027. It covers three battery categories only. Read how to read the timeline before you accept a date from a supplier.
Your European customer will compare your number with a competitor's number. If the two numbers measure different things, the comparison is wrong, and no machine reports an error.
The failure is a wrong comparison that no system reports
Take recycled content in a merino jumper. Two New Zealand suppliers answer the same question from the same buyer in Hamburg.
- Supplier A reports the recycled share by the weight of the finished jumper.
- Supplier B reports the recycled share by the weight of one component, the yarn.
Both suppliers send a percentage. Both label the field "recycled content". A machine reads the two fields, compares them, and returns a result.
Nothing in either system knows that the two numbers rest on different rules. That is the failure a shared model prevents.
A missing field is visible. A wrong comparison looks correct, which is why it survives.
EU law already measures recycled content in more than one way
Two European regulations use the phrase "recycled content" today. Each one measures it in a different way.
| Instrument | What it measures | Status |
|---|---|---|
| Regulation (EU) 2023/1542, batteries. Annex XIII points 1(e) and 1(f), with Article 8(1) | The recycled shares of cobalt, lithium and nickel in the active materials, and the recycled share of lead | Regulation in force. The passport duty applies from 18 February 2027 |
| Regulation (EU) 2025/40, packaging. Article 7 | The recycled content of plastic packaging, as an average for each manufacturing plant and each year | Applies from August 2026, with phased implementation |
Read the second row again. One figure is an average across a plant and a year. The other figure is a share of named metals inside one battery.
The packaging regulation makes the point itself. Article 12(4) requires a stated share of recycled content to follow the calculation method in Article 7(8). Read the official packaging text on EUR-Lex.
So a percentage carries a calculation method with it. If nobody writes the method down, your customer cannot check the number.
The public portal compares passports, so the words must agree first
The Ecodesign for Sustainable Products Regulation (ESPR) is Regulation (EU) 2024/1781, and it entered into force on 18 July 2024.
Article 14 of that regulation requires a publicly accessible web portal. The portal lets stakeholders search and compare digital product passport data.
Comparison is the exact operation that breaks without agreed meanings. Two entries that carry the same field name under two different rules produce a result that means nothing.
This site has found no opening date for that portal. See the EU passport portal.
The battery regulation requires full interoperability
Regulation (EU) 2023/1542 is in force, and Article 78(a) requires full interoperability. That article governs the battery passport alone, and no other passport.
The passport duty starts on 18 February 2027. It covers three categories:
- 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
Two systems cannot be interoperable on the connection alone. They must also agree what each field means at both ends. See EN 18223, system interoperability for the standard with that subject. See batteries for the scope of the duty.
This site names no data model, because no text it has read sets one
Warning: a supplier can name a model, a vocabulary or an ontology. Ask which document sets it. Then ask the status of that document.
Three gaps sit behind that warning.
The first gap is ESPR itself. This site has found no ESPR article that names a data model, a vocabulary or an ontology. ESPR does name the ISO/IEC 15459 series, for the data carrier and the unique product identifier. Annex III names parts 1 to 6. See product identifiers.
The second gap is the six cited standards. Each text is paywalled, and this site has read none of them. So this site states no requirement from any of the six. See the six standards and why the texts are paywalled.
The third gap is the registry implementing act. This site has now read the full act. The act names one source for the structure, the semantic repository that the Commission runs. It does not name a model for any product group.
The numbers of the six standards have a gap. Name them one by one:
- EN 18216
- EN 18219
- EN 18220
- EN 18221
- EN 18222
- EN 18223
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.
Commentary describes EN 18223 as a shared semantic data model, in which each data element points to a machine-readable definition in a semantic repository. That description comes from a CEN and CENELEC webinar deck, not from the standard. Treat it as reported, and not as confirmed. The same commentary does not say which repository the committee designates.
The registry act names one source for the structure, and it is free
Implementing Regulation (EU) 2026/1778 has been in force since 6 August 2026. It settles where the structure of passport data comes from. Article 11(3) reads:
All data contained within a digital product passport shall be structured in accordance with the common data models and semantic definitions published in the semantic repository referred to in Article 12.
Read that sentence as an exporter. The structure is not a matter for you, and it is not a matter for your software supplier. It comes from one repository that the Commission runs.
Article 12 sets what that repository must be and must hold.
| Article 12 requires | Detail |
|---|---|
| An authoritative source | For the data models, the semantic definitions and the vocabularies |
| Coverage | All product groups |
| Contents | The meaning of each data attribute, the models, their formats and their metadata |
| Labels | Multilingual labels and definitions for every mandatory attribute |
| A search service | Open to any user |
| Machine access | Through publicly documented interfaces, in common data formats |
| Price | Free of charge |
The last row is worth your attention, because the six cited standards cost money and the repository does not. Article 11(4) also requires the data models to be versioned, so a model can change after you build to it.
Warning: a requirement is not a delivery. This site did not fetch the repository, and it states nothing about what the repository holds today. The Commission user guide reports that the catalogue for batteries is not yet defined. See the EU registry.
That report has a legal consequence. Article 8(7) of the registry act makes the Commission check semantic conformity before it accepts a registration. So an empty repository for a product group blocks registration for that group.
The field list for your product group does not exist yet
ESPR is a framework regulation. It sets no data list for a product group until the European Commission adopts a delegated act for that group. The Commission has adopted no such act, as at 14 August 2026. See what a delegated act is and what data a passport holds.
GS1 described its own preparation at a webinar on 5 May 2026. It said the delegated act will set the terms in law. It said it builds a list of common terms and a list of apparel terms, such as colour fastness. It said it will then check those terms against the GS1 web vocabulary.
Mark that work for what it is. It is a plan for an industry project, and it binds nobody. No delegated act is adopted, so no term is set in law. ESPR does not name GS1.
Ask your customer how they define the value, and write it down
Warning: do not send a number without its definition. You cannot correct a comparison after a buyer has made it.
Do these five things on the next data request.
- Ask which document sets the field. Ask for the name and the article.
- Ask how the customer measures the value.
- Ask what the value is measured against, and in which unit.
- Write the definition next to the number in your own record.
- Send the definition with the number, in the same message.
Step 4 keeps its value for longest. A number in a spreadsheet with no definition beside it makes you do the work a second time.
You can do step 4 in a spreadsheet, and that works while one person keeps the file. The work gets harder when more than one person changes the record, and each buyer asks a different question. OwlQR, a New Zealand company that publishes this site, builds product record software. Ask any provider how its system stores a definition next to a value. Ask who may change that definition.
Then put the answers in the supply agreement. See how to agree data duties with your EU importer.
Start the definition work now, whatever the delegated act says
Food and drink sit outside ESPR, so no ecodesign passport reaches those products. Drink counts as food in EU law. See food and feed are excluded.
Warning: the food exclusion does not reach the packaging. Packaging is a separate good, and Regulation (EU) 2025/40 covers it. See packaging.
For every other product, start the definition work now. A delegated act cannot make a written definition wrong. It can only replace that definition with its own.
Do not buy a system on a claim of conformity with a named data model. This site cannot confirm which model the six standards name, because the texts are unread. See what this means for New Zealand exporters.