Foundations
What is not a digital product passport
A QR code to a marketing page, a PDF, a login portal, a spreadsheet or a blockchain entry is not a passport. Here is what each one lacks.
A QR code that opens a marketing page is not a digital product passport. A specification sheet in a PDF file is not one either.
A product page, a login portal, a spreadsheet of certificates and a blockchain entry also fail. Each one fails at least one of four tests. The tests ask for a code on the product, a machine answer, a different view for each reader, and data that outlives your company.
Here is what that costs you. You can buy a code for your merino jumper this year and put it on the label. You can still hold nothing your European customer can use.
A passport is structured data about one product. A code on the product leads to it, and each reader gets a different part of it. It must also stay available after your company stops trading. See what a digital product passport is.
The four tests, and where each one comes from
Two European laws matter here. The Ecodesign for Sustainable Products Regulation (ESPR) has been in force since 18 July 2024. The EU battery regulation, Regulation (EU) 2023/1542, is also in force. It carries the first binding passport duty in EU law.
| Test | Where it comes from |
|---|---|
| A code on the product leads to the data for that product | ESPR Annex III, on the data carrier and the unique product identifier |
| A machine reads the data, not only a person | Battery regulation Article 78(a), full interoperability |
| Each reader sees a different set of fields | Battery regulation Article 77(2), three groups of readers |
| The data outlives the company | Battery regulation Article 78(e) |
ESPR Article 14 requires a public web portal. Stakeholders can search and compare passport data there.
Warning: Article 77 and Article 78 govern the battery passport only. They do not govern the passport for any other product. For an ESPR passport, Article 10(e) of the ESPR covers the insolvency of the operator.
The battery duty applies from 18 February 2027. That duty 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
For any other product group, ESPR sets the fields through a delegated act. The European Commission has adopted none, as at August 2026.
A QR code that opens a marketing page holds no data
The code holds an address, with the data at the other end of it.
The battery regulation shows the difference in law. Article 13(6) gives every battery a QR code that leads to other information. Only the three categories above get a passport. So a QR code on a battery does not prove that a passport exists.
A PDF specification sheet cannot answer a machine
A customs system reads structured data. It cannot pull the fibre content of a jumper out of a page layout. See how a passport works.
The file also has no address on the product, and no version that a reader can check later. Article 77(4) of the battery regulation requires the information to be accurate, complete and up to date. A file that you send by email does not change after you send it.
A product page on your own website fails three of the four tests
It answers a person and not a machine. It shows the same content to every visitor. It stops when the site stops.
Article 78(e) of the battery regulation is direct:
the battery passport shall remain available after the economic operator responsible for the fulfilment of the obligations under Article 77(4) or (7) ceases to exist or ceases its activity in the Union
That is why a passport usually sits with a service provider, not on a company web server. See what happens if the company closes and passport versus product page.
A customer portal behind a login shuts out the public reader
Article 77(2) of the battery regulation names the general public as one of the three groups of readers. Article 78(b) requires free-of-charge access. That access follows the Annex XIII rights, and it follows the implementing act under Article 77(9) as well.
A login that you give to one buyer serves that buyer. It does not serve the public reader, or a recycler with a legitimate interest. See who can see what.
No text that this site has read bans a login outright. See what free access does and does not require.
A spreadsheet of certificates is a filing system
Certificates are part of a passport. The spreadsheet fails all four tests.
No identifier in it names one item. No code on the product reaches it. No machine can call it. No rule says who may read which row.
A supplier questionnaire ends when you return it
A buyer's questionnaire is a data request. It closes when you send it back.
A passport must stay up to date. Article 77(7) of the battery regulation requires a new passport for a repurposed battery. Article 77(8) ends the passport after the battery is recycled.
A blockchain record without a data model is storage, not a passport
The technology is not the test. Ask what the record holds, and who may read each field. The same question answers any other technology name, such as an Asset Administration Shell.
A ledger can help with one requirement. Article 78(g) of the battery regulation requires data authentication, reliability and integrity. It does nothing for the other three tests: no identifier on the product, no access tier for each reader, and no shared data model.
One of the six cited European standards, EN 18223, is titled "Digital Product Passport - System interoperability". This site has not read the six texts, because each one is paywalled. See the six standards.
A carbon label is one field
A carbon figure on a label is a single number, printed for a person to read.
The battery passport splits its content across three groups of readers. Annex XIII sets out that content over four numbered points. One number answers none of those groups in full.
A barcode names the model, not the item
A retail barcode holds a Global Trade Item Number (GTIN). ESPR Annex III(c) names the GTIN under ISO/IEC 15459-6.
A GTIN names a product model. Two identical e-bike batteries carry the same GTIN. Article 77(3) of the battery regulation requires a unique identifier for each battery.
ESPR names no vendor scheme. A search of the full regulation returns no hit for GS1, for Digital Link, for IEC 61406 or for the digital object identifier (DOI). What ESPR does name is in the table below.
| Point | What ESPR says |
|---|---|
| Annex III | The data carrier and the unique product identifier follow the ISO/IEC 15459 series, parts 1 to 6 |
| Article 10(1)(c) | Those standards apply, or equivalent European or international standards, until the references of harmonised standards are published |
A passport is not a certificate
This confusion costs money, because the conformity work does not go away.
Article 41(2) of the battery regulation lists what an importer must verify before it places a battery on the EU market:
- the EU declaration of conformity and the technical documentation are drawn up
- the manufacturer carried out the relevant conformity assessment procedure
- the battery bears the CE marking
- the battery is marked and labelled in accordance with Article 13
That list sits beside the passport, not inside it. See what a non-EU exporter must supply.
A registration in the EU registry is not proof of compliance
ESPR Article 13(1) requires a digital registry. The registry stores at least the unique identifiers.
| Date | What it is |
|---|---|
| 19 July 2026 | The statutory deadline in Article 13(1) |
| 20 July 2026 | The launch, with a testing environment |
The registry is now operational. A database is not a legal act, so do not read "operational" as "in force".
The registry does not store your product data. Article 10(c) requires the economic operator, or a passport service provider, to store it.
An operator uploads the registry data under Article 13(4), and the registry returns a unique registration identifier. Article 13(5) states that the registry's communication "shall not be deemed to be proof of compliance with this Regulation or other Union law".
No operator must upload anything yet, because no ESPR delegated act applies yet. A separate instrument, Implementing Regulation (EU) 2026/1778, governs the registry. That act is in force, and this site has now read all of it.
Article 9 of that act gives an operator a proof of registration. That proof is not proof of compliance either, and recital 16 of the act says so. See the EU registry.
What to ask before you buy
Warning: a product can pass all four tests and still be something you do not need this year. Check the rule for your product group first. See how to read the timeline.
- Ask what the identifier names: one model, one batch or one item.
- Ask for the machine answer, from the same address as the page.
- Ask which fields each reader sees. For a battery, expect three answers.
- Ask where the data goes if your company stops trading.
- Ask which of the six cited standards the product implements, by number. A supplier who writes them as a range names two standards that do not exist.
- Ask for the delegated act that covers your product group. Today there is none.
See what this means for New Zealand exporters for who is affected here.