Who reads a digital product passport, and what they want

A digital product passport has six readers. They are a consumer, a market surveillance authority, a customs authority, a repairer, a recycler and a business buyer. Most of them read with a computer system. The consumer reads the smallest part of the data.

Here is what that costs you if you get it wrong. If you design your passport as a marketing page, you build the wrong thing. An authority and a recycler then cannot read the data they need.

Two European Union (EU) laws name the readers. The Ecodesign for Sustainable Products Regulation (ESPR) is in force. It creates no passport duty for a product group until the European Commission adopts a delegated act for that group. The Commission has adopted no such act. The battery regulation is in force, and its passport duty starts in February 2027.

That duty covers each light means of transport battery, each industrial battery with a capacity greater than 2 kilowatt hours, and each electric vehicle battery. A light means of transport battery is the battery in an e-bike or an e-scooter. So the battery passport holds the only reader list that is in law today. See batteries for the scope.

Six readers, and what each one wants

A consumer reads the smallest part of the data

A person scans the QR code on an e-bike battery pack and gets a page to read.

The general public reads Annex XIII point 1. That point holds the battery label information, the rated capacity, the voltages and the expected lifetime in cycles. It also holds the recycled shares of cobalt, lithium, nickel and lead, the EU declaration of conformity and the waste management information.

Point 1(b) adds the material composition, and it names the battery chemistry inside it. Lithium iron phosphate is an example, so a consumer reads it and so does a competitor. Point 1(c) makes the carbon footprint information public too.

The consumer does not read your detailed composition. The cathode, the anode and the electrolyte materials sit in point 2, and point 2 is not public. See who can see what.

A consumer reads one item once. Serve that reader with the public data in point 1. The rest of the work in a passport serves the readers below.

A machine reads for almost everybody else

A person and a machine call the same address. The request states which answer it wants, and the service returns a page or structured data. See content negotiation.

An authority, a customs system, a recycler's system and a buyer's purchasing system take the second answer. A page written for a person does not give them the facts. A PDF file does not give them the facts either.

Article 78(a) of the battery regulation requires full interoperability. See how a passport works for the steps between the scan and the answer.

Authorities and notified bodies have their own tier

Article 77(2)(b) names notified bodies, market surveillance authorities and the Commission as one group. That group reads Annex XIII points 2 and 3.

A notified body is an organisation that carries out a conformity assessment where the law requires a third party.

Warning: one tier does not include the others. A person with a legitimate interest does not read point 3, and the authorities do not read point 4. See market surveillance and customs.

Point 2 holds the detailed composition, the part numbers, the dismantling information and the safety measures. Point 3 holds one item, the results of the test reports that prove the battery meets the regulation.

Customs read one identifier, not your passport

ESPR Article 15 is titled "Customs controls relating to the digital product passport". Under that article, customs receive the registration identifier for the product.

Two conditions limit that article. The registry must be operational, and a delegated act must cover the product. The Commission's registry became operational in July 2026. No delegated act covers any product group.

ESPR 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". So customs receive an identifier, and that identifier is not a certificate. See the EU registry.

A repairer wants parts and procedures

A repairer opens an e-bike battery pack and needs three things. The repairer needs the part number, the source of the spare and the way to take the pack apart. A repairer who cannot find those three things cannot finish the work, and that is the problem a passport is meant to solve. See what problem a passport solves.

Annex XIII point 2 holds all three. It names the part numbers for components, the contact details for sources of replacement spares and the dismantling information.

Point 2 is not public. A repairer reads it as a person with a legitimate interest. Article 77(9) required the Commission to adopt implementing acts that say who counts as such a person. The deadline in that paragraph is 18 August 2026. This site searched for them on 15 August 2026 and found none. See public data versus legitimate interest.

A recycler wants the materials, and then the passport ends

A recycler reads points 2 and 4, also as a person with a legitimate interest. Point 4 holds item-level values such as the state of health, the capacity fade and the round trip efficiency.

Two rules close the record. Article 77(7) requires a new passport for a repurposed battery. Article 77(8) says the passport "shall cease to exist after the battery has been recycled".

A passport thus has a start and an end. Other parties act on it after you sell the product.

A business buyer wants the evidence behind a claim

No passport rule makes your customer a reader. Your customer reads anyway, and asks by contract.

Take an e-bike battery sold through an importer in Rotterdam. Article 41(2) of the battery regulation tells that importer what to verify before it places the battery on the EU market:

• the EU declaration of conformity and the technical documentation
• the conformity assessment by the manufacturer
• the CE marking
• the marking and the label required by Article 13 of that regulation

The importer cannot verify what you did not send. ESPR Article 14 adds a public web portal where stakeholders can search and compare passport data. A buyer can put your entry beside a competitor's entry there. See the EU portal.

Decide who may read each field, and answer in the data

One address answers a person and a machine differently. Each field then needs one answer to one question, and the question is who may read this field.

Answer it in the data, not in the page design. For a battery today the three answers are the public, a person with a legitimate interest, and an authority or a notified body. For every other product group the answer comes from a delegated act, and no delegated act exists. See what a passport holds.

In New Zealand the first reader is a customer, not a regulator

You probably have no office in the EU. The operator that places your product on the EU market carries the duty. That operator is usually your importer.

So the reader you meet first is a European customer who asks for data as a condition of purchase. Because that request arrives before any law reaches your product, your customer sets the date and not the European Commission.

Three steps are useful for every product group.

1. Tag each data field with the reader who may see it.
2. Ask your EU customer which readers they must answer, and by when.
3. Write those answers into the supply agreement, with a named person on each side.

See if you supply a component, how to agree data duties and what this means for New Zealand exporters.