The standards
What Standardisation Request M/604 is, and why it matters
Standardisation Request M/604 is the European Commission instruction to CEN and CENELEC to write the digital product passport standards.
Standardisation Request M/604 is the instruction that committee CEN/CLC/JTC 24 answered with the digital product passport standards. The European Commission sent it to CEN and CENELEC, which set up that committee. The six published passport standards exist because the Commission made that request.
If you ignore this, you will misread what those standards can do for you. They describe how to build a passport. They do not tell you if your product needs one. They do not list the data your product must carry.
The Commission does not write the standard itself
The European Commission writes law. It does not write a technical document such as a data format or an identifier rule. For that work it asks a European standards body.
CEN and CENELEC are those bodies. The Commission sent them Standardisation Request M/604. An amendment, M/604_Amd1, followed.
The chain from the request to a legal effect has five steps.
- The Commission issues a standardisation request to CEN and CENELEC.
- CEN and CENELEC set up a committee to answer the request.
- The committee writes the standards, and CEN and CENELEC publish them.
- The Commission may then cite a published standard in the Official Journal.
- A product built to a cited standard gets a presumption of conformity.
That chain gives a voluntary technical document a legal effect without making it mandatory. A harmonised standard stays a document that you may use or ignore.
CEN/CLC/JTC 24 answered the request and wrote eight standards
| Item | Detail |
|---|---|
| The request | Standardisation Request M/604 |
| The amendment | M/604_Amd1 |
| The committee | CEN/CLC/JTC 24, Digital Product Passport - Framework and System |
| The secretariat | DIN |
| Standards produced | Eight |
| Published and cited | Six |
| Still under approval | Two |
The committee is CEN/CLC/JTC 24. It answered the request, and it wrote every standard named on this page.
Six standards from the request are cited, and two are not
Name the six. The numbers have a gap, and a range invents two documents that do not exist.
- EN 18216, data exchange protocols
- EN 18219, unique identifiers
- EN 18220, data carriers
- EN 18221, data storage, archiving, and persistence
- EN 18222, application programming interfaces for product passport lifecycle management and searchability
- EN 18223, system interoperability
Warning: there is no EN 18217 and no EN 18218 in this set. A person who orders by a range cannot tell which documents to order. Which standards apply gives the official title of each one.
The same request produced two more standards, and both are drafts. Neither prEN 18239 nor prEN 18246 is published or cited, so neither gives a presumption of conformity today.
| Step | Date and status |
|---|---|
| The six standards published | Late May 2026. The British Standards Institution catalogue gives 28 May 2026. |
| The citing Decision adopted | 14 July 2026, adopted |
| The citing Decision in force | 15 July 2026, in force |
| Formal vote closed on the two drafts | 16 July 2026. Both still under approval. |
Citation gives a presumption of conformity, not a duty
A citation does not make a standard mandatory. It gives a product built to that standard a presumption of conformity. An authority then treats that product as compliant with the requirement the standard covers.
You may meet the same requirement another way. You must then show your own evidence.
| Item | Where it comes from |
|---|---|
| The request for the standards | Standardisation Request M/604, with M/604_Amd1 |
| The citation of the six standards | Implementing Decision (EU) 2026/1736 |
| The legal basis of that Decision | Article 10(6) of Regulation (EU) No 1025/2012 on European standardisation |
| The presumption of conformity | Article 41(2) of Regulation (EU) 2024/1781, the ecodesign regulation |
Read the Decision text in the Official Journal.
This site has not read the request
Three things about M/604 are unknown here.
- Nobody on this site has read the full text of the request.
- The detailed list of deliverables in the request is unknown here.
- The deadlines that the request set are unknown here.
So this site does not state what M/604 demanded, or when it demanded it. It states the identity of the request, the committee that answered it, and the standards that came out of it.
The six standard texts are unread here as well, because each one is paywalled. The page on why the texts are paywalled explains the cost. This site thus states no requirement from any of the six.
The standards do not decide if you need a passport
The request sets the scope of the work. A subject that the request left out is a subject the standards do not cover.
The split shows in the law. The presumption of conformity covers Articles 10 and 11 of the ecodesign regulation. It does not cover Article 9, the article that makes a passport a condition of market access.
GS1, an industry standards body, described the same split in an apparel webinar of 5 May 2026. It called one side the system, and the other side the data. The system is the infrastructure, and a delegated act defines the data for each product group. Treat that description as industry material, not as law.
So the standards tell you how to build a passport. The delegated act for your product group tells you if you need one, and what goes inside it.
A merino jumper needs no passport, and an e-bike battery needs one in 2027
Take a merino jumper sold into Germany. No textile delegated act is adopted, so no passport rule reaches that jumper today. The six standards are published, and they create no duty for it. The page on textiles gives the dates and their status.
An e-bike battery is different. The battery regulation is in force, and it names three categories of battery. An e-bike battery is a light means of transport battery. No size limit applies to that category, so the duty covers an e-bike battery of any size.
| Item | Detail |
|---|---|
| The instrument | Regulation (EU) 2023/1542, Article 77. In force. |
| The duty starts | 18 February 2027 |
| Category one | Each light means of transport battery, such as an e-bike battery |
| Category two | Each industrial battery with a capacity greater than 2 kilowatt hours |
| Category three | Each electric vehicle battery |
Article 13(6) gives every battery a QR code. For a battery outside the three categories, that QR code goes to other information. It does not go to a passport. The page on batteries gives the detail.
Neither case depends on M/604. The request started the work on the passport standards. The law for your product decides if you need a passport.
Check if a law covers your product group before you buy a standard
Warning: do not buy a standard because a supplier says that the law requires it. Check first if a rule covers your product group.
- Ask a supplier which numbered standard its product implements.
- Ask that supplier to quote the purchased text for any scope claim.
- Monitor for the delegated act for your product group.
- Work to the battery date if you sell a battery.
You have one more step as a New Zealand exporter. Ask your European customer what data they will need, and when. What this means for New Zealand exporters sets out that conversation, because a purchase condition can reach you before any law does.