What law creates the digital product passport

Two European laws create digital product passports, not one. The Ecodesign for Sustainable Products Regulation (ESPR) is the frame, and the battery regulation's Article 77 sets the one passport duty, from 18 February 2027.

If you plan against the wrong law, you will spend money years early. The ecodesign regulation creates no passport duty for any specific product.

The ecodesign regulation sets the mechanism, and the battery regulation sets the date

The ecodesign regulation is Regulation (EU) 2024/1781. It is in force. It sets the mechanism for a passport: what a passport must do, who must hold it, and how the European Commission can require one. See what is the ESPR for the full regulation.

Article 1(2) puts some products outside that regulation fully. Food, feed and medicinal products are on the list. What Article 1(2) excludes gives the full list. If your product is on that list, no ecodesign passport duty reaches it at any date.

The regulation also names a list of priority product groups, such as iron and steel, textiles and furniture. A place on that list gives your product no duty and no date. A standards body publishes the list, and this site has not read the article behind it. Which product groups are priorities gives the wording and the source.

The regulation requires a passport for no product today. The duty starts only through a separate rule for each product group. That rule is a delegated act. As at August 2026 the Commission has adopted no such rule for any group.

The battery regulation is Regulation (EU) 2023/1542. It is a complete law in its own right. Its Article 77 sets a passport duty with a fixed date, and that date does not depend on any ecodesign act.

The battery regulation is the only binding passport duty

Article 77(1) reads:

From 18 February 2027 each LMT battery, each industrial battery with a capacity greater than 2 kWh and each electric vehicle battery placed on the market or put into service shall have an electronic record ('battery passport').

The regulation names three battery categories and no others:

• 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

Read the first item again. It carries no size threshold. A Commission news item of 20 July 2026 uses the phrase "large batteries" for this rule, and that phrase is loose. An e-bike battery is small, and the passport duty covers it.

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

The duty is per item, not per model. A repurposed battery needs a new passport. The passport ceases to exist after the battery is recycled.

Article 13(6) gives every battery a QR code. For a battery outside the three categories, that code leads to other information. It is not a passport. The full rule is in the battery regulation.

Four kinds of instrument decide your date

European law comes in four kinds of instrument. If you confuse them, you get your date wrong.

The delegated act is the instrument that affects you most. It names your product group, lists the data fields, and sets your date. A delegated act cannot apply earlier than 18 months after it enters into force. The text allows exceptions, so treat that period as the usual case and not as a guarantee.

How to read the timeline does the arithmetic for each sector. An implementing act is different. It does not create the duty. It settles how an authority applies an existing duty.

A harmonised standard stays voluntary

A harmonised standard is not a law, and nobody has to use one.

Citation in the Official Journal does not make a standard mandatory. It gives a product built to that standard a presumption of conformity. An authority then treats the product as compliant with the legal requirement.

Implementing Decision (EU) 2026/1736 does not rest on the ecodesign regulation

Implementing Decision (EU) 2026/1736 rests on a different law, which changes what the Decision can do.

That split matters to you. Article 9 makes a passport a condition of placing a covered product on the market. The other two articles carry the technical requirements. Until a delegated act covers your product group, the presumption gives you nothing in practice.

The Decision cites six standards. Name them one by one, because the numbers have a gap.

There is no EN 18217 and no EN 18218 in this set. A range written as "EN 18216 to EN 18223" invents two standards that do not exist. If you read the range, you cannot tell which six standards to build to.

The six standards describes each one. Read the Decision text in the Official Journal.

The ecodesign regulation names no vendor scheme

A search of the full regulation returns no hit for GS1, for Digital Link, for IEC 61406 or for a digital object identifier. The search covered the recitals, the articles and the annexes. The regulation does not name ISO/IEC 18004, the QR code standard, either.

Annex III names the ISO/IEC 15459 series. The regulation lists parts 1 to 6. Article 10(1)(c) makes that an interim rule. It allows those standards, or equivalent European or international standards, until the references of harmonised standards are published.

So a supplier who tells you that the ecodesign regulation requires a GS1 Digital Link address is wrong about the source. Identifier schemes sets out what is verified and what is still behind a paywall.

The regulation also creates a registry and a portal

Article 13(1) required the Commission to set up a digital registry by 19 July 2026. That registry stores at least the unique identifiers. It is operational, and it holds no passport. The passport data stays with the operator.

Article 13(4) requires the operator to upload the registry data, and Article 13(5) states that the registry's communication is not proof of compliance. So a registration identifier is not a certificate. No operator must upload anything yet, because no delegated act applies yet. The EU passport registry sets out who uploads, and when.

Article 14 requires a public web portal. It lets people search and compare passport data. The EU passport portal explains how the portal differs from the registry.

The old ecodesign directive is not fully repealed

The ecodesign regulation repeals Directive 2009/125/EC. Its Article 79 keeps some articles and annexes of that Directive in effect for transitional purposes.

So a statement that the old Directive lost all effect in July 2024 is wrong. Check your product before you assume that only the new regulation reaches it.

If you sell one of the three kinds of battery, your deadline is 18 February 2027

If you sell a battery in one of the three categories, you have a real deadline. It is 18 February 2027, and it applies to each battery, so start now.

A covered product without a passport cannot lawfully go on the European market. That lost market access arrives before any penalty. What happens if you do not comply states what this site can and cannot tell you about penalties.

If you sell anything else, no European passport duty reaches your product today. Monitor for the delegated act for your product group, not for the published plan.

If you sell food or drink, the ecodesign regulation excludes your product. See food and feed are excluded.

The operator who places the product on the European market carries the duty. If you have no European office, that is usually your importer. What a non-EU exporter must supply lists what your importer will ask you for.