The technical standards are here — and they carry more weight than expected
At the beginning of June 2026, the DPP4EU Conference in Brussels unveiled the result of more than two years of standardization work: CEN and CENELEC have published the first harmonized European standards for the Digital Product Passport — the EN 18216 to EN 18223 standard series, developed under the umbrella of CEN/CENELEC JTC 24. At the same time, open-source test environments were introduced that allow implementations to be checked for conformance.
This is not a symbolic gesture. Since the adoption of ESPR Regulation (EU) 2024/1781, the Digital Product Passport is binding EU law. The standard series now provides the technical foundation on which sector-specific implementing regulations will be built. Anyone who ignores these standards risks building a proprietary infrastructure that will need to be retrofitted later.
What the EN 18216–18223 standard series actually covers
The standards address four core areas:
- Core data model and vocabulary (EN 18216/18217): definitions, data structures, minimum attributes
- Data carriers (EN 18220): requirements for physical and digital carriers — QR code, RFID, NFC
- Unique identifiers (EN 18219): identifier structure, resolver mechanism
- APIs and interoperability (EN 18221–18223): interfaces between registries, economic operators, and authorities
EN 18219 in particular is politically sensitive: the CIRPASS-2 consortium explicitly recommends in its position paper on the draft implementing regulation that this standard be included as a reference. The background: EN 18219 is formulated in a technology-neutral way, but includes GS1 Digital Link as a conformant identifier mechanism. The consortium also criticizes the governance structure of the central registry and unresolved questions around data sovereignty in cross-border supply chains.
The JRC draft for semi-finished steel products: a blueprint for industrial goods
While the standards set the framework, the Joint Research Centre of the European Commission is spelling out what that means for individual sectors. The JRC draft for semi-finished iron and steel products is significant for several reasons — and not only for the steel industry.
Batch level versus item level: a critical architectural decision
The draft systematically distinguishes between data that must be maintained at the item level (by serial number) and data maintained at the batch level (by lot number):
| Data level | Identifier | Example data |
|---|---|---|
| Batch level (Lot) | Lot number | Recycled content, alloy composition, product carbon footprint (PCF) |
| Item level (Item) | Serial number | Dimensions, certifications, declarations of conformity |
This distinction is critical for database architecture and identifier strategy. The product carbon footprint is calculated according to rules compatible with the ISO 14067 standard — an established framework for product carbon footprints.
For comparison: the Battery Regulation (EU) 2023/1542 — currently the only binding sector act with its own DPP obligations — already implies this distinction without formalizing it so clearly. The steel draft sets a precedent that is likely to be relevant for all future sector acts: textiles, electronics, furniture.
Why this matters for IT architects right now
If you are planning a DPP infrastructure today, you should build the lot-versus-item logic into your data model from the start. A flat structure that tracks all attributes at the item level will need to be retrofitted when batch-level attributes such as the PCF are introduced — with the corresponding migration effort. Systems that support bulk import for large product volumes must be able to represent this hierarchy.
GS1 Digital Link in practice: from fresh produce to RFID
Alongside regulatory developments, early pilot projects are showing how the technical standards are playing out in the real world.
Driscoll's and Antares Vision: serialization for berries
At GS1 Connect 2026, Antares Vision Group and Driscoll's presented a joint pilot for item-level serialization in the fresh produce segment. The key feature: proprietary QR codes are being replaced by universally readable data carriers based on GS1 Digital Link. This is no small step — fresh produce is considered one of the most demanding test cases for serialization systems due to short shelf lives and high scan volumes.
TEKLYNX CODESOFT: GS1 web URLs in RFID tags
Another real-world signal comes from TEKLYNX: the updated CODESOFT software now supports the GS1 encoding schemes EPC++ and ISO BD. This makes it possible to write web URLs directly into RAIN RFID tag memory — a requirement that follows from the combination of EN 18220 (data carriers) and the GS1 Digital Link standard.
This is technically significant: until now, RFID tags typically stored binary-encoded EPCs that required a separate lookup step to resolve to a URL. With EPC++, that intermediate step is eliminated — the tag itself contains the resolvable address of the digital product passport.
GS1 US and Extended Producer Responsibility
Also in June, GS1 US published a guideline on using GTINs and GLNs to comply with state-level Extended Producer Responsibility laws for packaging. The guideline targets companies in healthcare, food, and retail. Relevant for the European context: the underlying logic — standardized identifiers as the basis for compliance reporting — is the same logic that underpins the EU DPP registry.
REACH microplastics: first reporting deadline now in effect
Somewhat outside the DPP debate, but directly relevant for manufacturers of plastic products: ECHA published guidance in May 2026 on the REACH reporting obligation for synthetic polymer microparticles. The first reporting deadline for manufacturers and industrial downstream users of polymer pellets, flakes, and powders has now taken effect.
The connection to the DPP is not direct, but it is structural: both regulatory frameworks require the digital documentation of material properties along the supply chain. Companies building DPP-ready data management today should assess whether REACH reporting data can be integrated into the same system — this reduces duplication and creates a consistent data foundation.
What companies should do now
The developments of recent weeks add up to a clear picture: the Digital Product Passport is no longer a pilot project — it is a regulatory program with concrete standards, initial sector drafts, and growing tooling support.
Three areas of action are immediately relevant:
Evaluate the EN 18216–18223 standard series: EN 18219 (identifiers) and EN 18220 (data carriers) in particular are critical for technical architecture. The standards are available through national standards bodies.
Anchor lot-versus-item logic in your data model: The JRC steel draft is an early indicator. If you operate in industrial sectors, you should treat the batch level as a distinct data entity today.
Evaluate GS1 Digital Link as your identifier standard: The convergence of EN 18219, RFID encoding (EPC++), and the GS1 Connect pilots shows that GS1 Digital Link is becoming the de facto preferred implementation option — even though the standards are written in a technology-neutral way.
The DPP4EU Conference made it clear: the standardization phase is complete. The implementation phase starts now.
