Foundations
What data a digital product passport holds
It depends on the product group. The EU battery regulation sets a full data list, and this page sets that list out.
Each product group gets its data list from its own rule. For a battery, the digital product passport carries every field in Annex XIII of the EU battery regulation, which is in force. The Ecodesign for Sustainable Products Regulation (ESPR) sets no data list for any product group yet.
Here is what that costs you. If you buy a system built to a field list that somebody guessed, you pay for it twice. You pay now, and you pay again when the real list arrives.
A passport is structured data about one product, reached from a code on the product. See what a digital product passport is if that is new.
The battery regulation names data fields, and the ecodesign regulation names none
| Instrument | Status |
|---|---|
| Ecodesign for Sustainable Products Regulation (ESPR), Regulation (EU) 2024/1781 | In force since 18 July 2024. It names no data fields for any product group. |
| Battery regulation, Regulation (EU) 2023/1542 | In force. Its passport duty starts on 18 February 2027. |
If you export a detergent, a toy or a construction product, your passport duty comes from that product's own regulation. That regulation is not the ecodesign regulation. This page does not set out those fields.
No field list exists for any ecodesign product group
Warning: a supplier who shows you a textile field list today shows you a guess. Read how to read the timeline before you accept a date. Read which products need a passport before you accept a scope.
ESPR is a frame. It creates the passport, and it leaves the content to a later rule for each product group. That later rule is a delegated act.
The European Commission has adopted no delegated act for any product group, as at August 2026. So no ecodesign field list exists for textiles, for furniture, for steel, for tyres or for anything else.
The battery passport is the one worked example
The battery regulation is a separate law, and it is in force. Article 77 requires a battery passport. The duty starts on 18 February 2027. It covers these 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
Article 77(3) requires a unique identifier for each battery. So one passport belongs to one physical battery rather than to a model or a batch. See batteries for the scope and the date.
Annex XIII sets every field the battery passport carries
Annex XIII of the battery regulation sets the content. Article 7(1) adds the carbon footprint declaration.
| Subject | What the passport carries | Where the rule sits |
|---|---|---|
| Identity and label | The manufacturer identification, the battery category and identification, the place of manufacture, the date of manufacture and the weight | Annex XIII point 1(a), which refers to Annex VI Part A |
| Performance | The voltages with their temperature ranges, the original power capability and the expected lifetime in cycles | Annex XIII points 1(g) to 1(p) |
| Recycled content | The recycled shares of cobalt, lithium, nickel and lead, and the share of renewable content | Annex XIII points 1(e) and 1(f) |
| Responsible sourcing | The information in the battery due diligence policy report | Annex XIII point 1(d) |
| Carbon footprint | The declaration, with the manufacturing plant location and the footprint figure | Article 7(1), and Annex XIII point 1(c) |
| Composition, public | The material composition, including the battery chemistry, the hazardous substances other than mercury, cadmium and lead, and the critical raw materials | Annex XIII point 1(b) |
| Composition, restricted | The detailed composition, meaning the materials used in the cathode, the anode and the electrolyte | Annex XIII point 2(a) |
| Repair and dismantling | The part numbers, the spare part contacts, the dismantling information and the safety measures | Annex XIII point 2 |
| Condition in service | The item-level performance and durability values, the state of health, the status of the battery, and the data from its use | Annex XIII point 4 |
| Marking | The marking requirements in Article 13(4) and (5) | Annex XIII point 1(q) |
| Conformity, public | The EU declaration of conformity | Annex XIII point 1(r) |
| Conformity, restricted | The results of the test reports. Only notified bodies, market surveillance authorities and the Commission read these | Annex XIII point 3 |
Warning: two composition rows sit in two different tiers, and summaries collapse them into one. The battery chemistry is public. Lithium iron phosphate is an example, and a competitor can read it. Which materials you use in the cathode, the anode and the electrolyte is not public.
Note the marking row. A corrigendum of 10 April 2026 changed the cross-reference in point 1(q). It now points at Article 13(4) and (5). The old reference to Article 13(3) and (4) is still in circulation, so check any copy you are given.
One row in that table changes after you ship the product. The state of health of an e-bike battery falls with use, and the passport must follow it. Article 77(8) ends the passport after somebody recycles the battery. See lifecycle events.
Three groups of readers each see a different part of the passport
The passport holds more data than any one reader sees. Article 77(2) splits the content across three groups of readers. See who reads a passport for the six readers and what each one wants.
| Reader | Annex XIII points |
|---|---|
| The general public | Point 1 |
| Notified bodies, market surveillance authorities and the Commission | Points 2 and 3 |
| Any person with a legitimate interest | Points 2 and 4 |
The three groups are not nested, and a bigger group does not contain a smaller one.
Your detailed composition sits in point 2, so the public does not read it. Your battery chemistry sits in point 1, so the public does read it. Read who can see what before you decide what to publish.
The battery table splits into identity data and product facts
Warning: this split describes the battery passport only. No source says that another product group will use the same split.
Look again at the table above. The first row is identity data. It answers what the battery is, who made it and where.
Every other row is a product fact. A product fact answers what the battery is made of, how it performs, and what to do with it at the end.
Every passport needs an identifier and a data carrier
ESPR sets no fields, but it does set a rule for the identifier and the data carrier.
Warning: 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). Some suppliers state that ESPR requires a GS1 Digital Link web address. The text does not say that. See product identifiers.
Annex III requires the data carrier and the unique product identifier to comply with the ISO/IEC 15459 series. The rule names parts 1 to 6. It applies where it is relevant for the products concerned. Annex III(c) names the Global Trade Item Number (GTIN) under part 6.
Article 10(1)(c) makes this an interim rule. It allows those standards, or equivalent European or international standards, until the Commission publishes the references of harmonised standards.
What this site does not know about passport data
This site names three gaps, because a supplier may fill them for you.
- The fields for any ESPR product group. No delegated act exists.
- What the six cited European standards require. Each text is paywalled, and this site has not read one. See the six standards.
- How many product identifier schemes EN 18219 permits. Commentary states a number. The standard is unread. See identifier schemes.
This site closed one gap. It read Annex XIII point 3, and the table above carries that content. See what this site does not know for the rest.
Do not buy a system built to a guessed field list
Warning: you must rebuild a system that you built to a guess, once the delegated act arrives. Ask four questions before you sign.
- Ask which regulation sets each field. For a battery, expect Annex XIII.
- Ask which of the six standards the product implements, by number.
- Ask how the system holds a field that changes after the sale.
- Ask how the system separates the three groups of readers.
A supplier who writes the standards as a range names two standards that do not exist. There is no EN 18217 and no EN 18218. These are the six standards.
| Standard | Subject |
|---|---|
| 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 |
Use Annex XIII for a battery, and your own records for every other product
Food and feed products sit outside ESPR, and no passport rule reaches them. Drink counts as food in EU law. See food and feed are excluded.
The exclusion applies to the product, not to the company. Your other products may still fall in scope. Packaging is a separate product, and the food exclusion does not reach it.
If you export a battery in one of the three categories, work from Annex XIII now. The date is close, and the duty covers each individual battery.
For every other product, do the work that no field list can change. Write down where each fact about your product lives, and name the person who owns it. See what this means for New Zealand exporters.