How it works
Verifiable credentials and blockchain are not required
No verified EU instrument requires a verifiable credential or a blockchain. The one binding duty asks for data authentication and names no method.
No EU rule in this site's sources makes a verifiable credential or a blockchain mandatory for a digital product passport. The one binding duty on this subject sits in Article 78(g) of the battery regulation. It requires data authentication, reliability and integrity, and stops there.
Here is what that costs you. You can buy a signing system this year for a merino jumper, and no adopted rule covers that jumper. Read how to read the timeline before you sign for one.
A verifiable credential still does useful work, because it shows a reader who asserted a figure.
A signature answers a reader who cannot telephone you
Take an e-bike battery built in Christchurch and sold in Germany. A recycler opens its passport and reads the cathode composition. The recycler must then decide if to trust that figure.
Two questions sit inside that decision. One asks who asserted the figure. The other asks if anybody changed the figure afterwards.
A verifiable credential answers both questions. The issuer signs the data with a private key. A reader checks the signature with the public key. A changed figure breaks the signature, and the reader sees that. The World Wide Web Consortium publishes the specification behind the term.
So the technology has a purpose, but the legal question is separate.
The binding duty asks for authentication and names no method
The battery regulation is Regulation (EU) 2023/1542, and it is in force. Its passport duty applies from 18 February 2027. It covers three battery categories:
- a light means of transport (LMT) battery, such as an e-bike battery
- an electric vehicle battery
- an industrial battery with a capacity greater than 2 kilowatt hours
Warning: an LMT battery carries no size threshold. Do not use the word large as a test of scope. See batteries for the detail.
Article 78 sets the technical essential requirements for the battery passport. Point (g) requires data authentication, reliability and integrity. The text stops there. It names no specification, no product and no supplier.
Warning: Article 78 governs the battery passport alone.
The table gives every provision this page uses.
| Provision | Instrument | What it requires | Status |
|---|---|---|---|
| Article 78(g) | Regulation (EU) 2023/1542 | Data authentication, reliability and integrity | Applies from 18 February 2027 |
| Article 77(4) | Regulation (EU) 2023/1542 | The information is accurate, complete and up to date | Applies from 18 February 2027 |
| Article 78(e) | Regulation (EU) 2023/1542 | The passport stays available after the operator ceases to exist | Applies from 18 February 2027 |
| Article 10(c) | Regulation (EU) 2024/1781 | The operator or a service provider stores the passport | In force. The duty starts with a delegated act. |
| Recital 41 | Regulation (EU) 2024/1781 | A decentralised data system | In force. A recital states intent, not a duty. |
Regulation (EU) 2024/1781 is the Ecodesign for Sustainable Products Regulation (ESPR), in force since 18 July 2024.
A signature proves the source, and not the truth
Article 77(4) sets the duty that sits next to authentication:
The economic operator placing the battery on the market shall ensure that the information in the battery passport is accurate, complete and up to date.
A signature shows that the operator asserted a figure, and that nobody changed the figure since. It says nothing about if the figure is right. A wrong carbon figure, signed, stays a wrong carbon figure.
So a credential meets none of the three accuracy tests on its own. See who is liable if the passport data is wrong.
The data authentication standard is a draft, and it is not cited
CEN and CENELEC are European standards bodies. Their joint committee produced eight passport standards. Six of them are published, and the Official Journal cites those six.
Warning: this site has not read the six published texts, because each one is sold. So this site states no requirement from any of them. None of the six carries data authentication in its title. See the six standards.
The draft on data authentication is prEN 18246. Its formal vote closed on 16 July 2026. CEN and CENELEC still show the document as under approval.
So the Official Journal does not cite it. A product built to that draft gains no presumption of conformity today. See prEN 18246 for the draft and its reported contents.
Decentralised in the regulation means the data stays with you
ESPR uses the word decentralised, and that word does not mean a blockchain.
Article 10(c) requires the passport to be "stored by the economic operator responsible for its creation or by digital product passport service providers". Recital 41 requires "a decentralised data system".
Read those two points as a rule about who holds the data. The passport data stays with the operator or with a service provider. The European Commission runs a registry, and that registry stores at least the unique identifiers. The registry became operational in July 2026.
A search of the full regulation returns no hit for "decentralised identifier". The search covered the recitals, the articles and every annex. See what is verified about identifier schemes.
No text in this site's sources names a blockchain as a passport requirement. A blockchain also answers one question only. It gives you no identifier on the product, no access rule for each reader and no shared data model. See what is not a digital product passport.
The same holds for the Asset Administration Shell, which is a data pattern and not a duty.
What to ask a supplier who sells a credential or a blockchain
Warning: do not accept the phrase "meets the EU requirements" for an authentication product. Ask for the requirement by its number.
- Ask which instrument requires this technology. Ask for the article number.
- Ask if that instrument is in force, adopted or draft.
- Ask which of your product groups it covers, and from which date.
- Ask what happens to the verification after your company stops trading.
- Ask for the price of the same passport without the signing feature.
Expect the honest answer to question one to be none yet. Question four matters because Article 78(e) keeps a battery passport available after the responsible operator ceases to exist. See what happens if the company closes.
Your EU importer usually chooses the system, so ask if it needs signed data from you
A New Zealand manufacturer with no establishment in the Union does not place the product on the EU market. The EU importer does that, and the importer carries the Article 77(4) duty. See who is the economic operator.
So the system choice is usually your importer's choice. Put one question to that importer. Ask if its passport system will need signed data from you, and from which date.
If the answer is no, buy nothing this year. If the answer is yes, the importer names the format, because the importer answers for the data.
This site holds no published price for this work either. No passport pilot has published a cost, a time or a benefit figure. See what a passport costs.
What this site searched, and what came back, is listed in what this site does not know.
ESPR excludes food, and food includes every drink. So no ESPR passport duty reaches a wine product. The exclusion covers the product, and not the company. Another product from the same company can still be in scope. See what this means for New Zealand exporters.
This page changes if the Official Journal cites the draft
One event changes the answer above. If the Commission cites prEN 18246, a product built to that standard gains a presumption of conformity. The standard itself stays voluntary.
Warning: this site has not confirmed that a citation under ESPR would reach Article 78(g) of the battery regulation. The two regulations are separate instruments.
Until the Official Journal cites prEN 18246, a verifiable credential and a blockchain stay design choices. Either one can still be right for your product. No adopted rule makes either one the law.