What Was Published — and Why It Matters
On May 28, 2026, national standards bodies — including the Belgian NBN — officially published the first harmonized European standards for the Digital Product Passport (DPP). They were developed by Technical Committee CEN/CENELEC JTC 24, which has been working since 2023 on cross-sector standards for interoperability and data consistency.
The three standards published in May form the technical foundation for every compliant DPP:
| Standard | Title (short form) | Core content |
|---|---|---|
| EN 18219:2026 | Unique Identifiers | How products are uniquely identified — syntax, persistence, collision-free assignment |
| EN 18220:2026 | Data Carriers | Which physical carriers (QR code, RFID, DataMatrix) are permitted and how they must be encoded |
| EN 18222:2026 | Interoperability Framework | Semantic and technical requirements for cross-system data exchange |
On June 25, 2026, CEN and CENELEC held a public webinar on the newly published standards EN 18216 through EN 18223 — the complete package of standards developed by JTC 24. Together, the six standards define the cross-sector framework that manufacturers, importers, and software providers will need to reference going forward.
What the Standards Actually Cover
EN 18219: Unique Identifiers
EN 18219 requires that every DPP carry a persistent, globally unique identifier. In practice, this means a product receives an identifier that remains unchanged throughout its entire lifecycle — manufacturing, use, repair, recycling — and points to the associated data record.
The standard does not mandate proprietary systems; instead, it defines requirements that established identification schemes such as the GS1 Digital Link can satisfy. A GS1 Digital Link encodes a GTIN and serial number in a standardized URI and links directly to the DPP data record — an approach already being piloted in the battery industry.
EN 18220: Data Carriers
EN 18220 governs which physical data carriers may be used to convey the identifier on the product. QR codes, DataMatrix, and RFID tags are recognized as compliant carriers, provided they meet the encoding requirements defined in the standard. Critically, the carrier must not only be readable but also permanently affixed to the product — labels that peel off after first use do not qualify.
If you already use dynamic QR codes, note that EN 18220 takes no position on whether the data record behind the code may be static or dynamic. That question is governed by sector-specific regulations — such as the Battery Regulation.
EN 18222: Interoperability
EN 18222 is the most demanding of the three standards. It defines how DPP systems from different vendors and countries must communicate with each other, so that a customs officer in Rotterdam can read the same passport as a recycling company in Poznań. Specifically, the standard sets requirements for:
- Data models: Fields must be semantically unambiguous, not merely syntactically correct.
- API interfaces: Systems must support standardized queries.
- Access rights: Not all data points are visible to all actors — the standard distinguishes between public, restricted, and confidential data areas.
Embedding in the Regulatory Framework
These three standards do not exist in a vacuum. They are part of the implementation of the Ecodesign for Sustainable Products Regulation (ESPR), which introduces the DPP as a cross-sector instrument. For batteries, the specific requirements of the Battery Regulation (EU) 2023/1542 apply in addition.
The Battery Regulation explicitly requires that certain data points remain updatable throughout a battery's entire lifecycle. State of Health (SoH) and State of Charge (SoC) change with every charge and discharge cycle. For batteries used in a second life — for example as stationary storage after service in an electric vehicle — up-to-date condition data is not only a regulatory requirement but also commercially significant.
If you populate your passport once at the point of placing the product on the market and never update it again, you will not fully meet the requirements — and from February 18, 2027 onward, you risk serious compliance issues. That deadline applies to industrial batteries of 2 kWh and above and traction batteries for electric vehicles.
Structural Weaknesses Across the Industry
The Minespider Implementation Report 2026 identifies two structural weaknesses that run across the entire industry: data fragmentation along the supply chain and the absence of processes for dynamic data updates. EN 18222 addresses both problems directly — but it does not solve them on its own. The standard creates the technical foundation; companies must build the internal processes themselves.
Test Environment and Registry: The Operational Context
In parallel with the publication of the standards, the BatteryPass-Ready consortium launched a public test environment for the Digital Battery Passport on June 24, 2026. Manufacturers and system integrators can use it to verify whether their DPP implementations meet the requirements of the new standards — an important step before the obligation takes effect.
On the regulatory side, the European Commission is working on a central registry through which all DPPs will be registered and made discoverable. Orgalim — the European industry association for technology — has published clear recommendations on this: the registry must support high-volume, automated registration processes and be protected against operational outages. For manufacturers with millions of products, a manual registration process is simply not feasible — the infrastructure must support mass imports, such as those enabled through bulk import interfaces.
What Manufacturers Need to Do Now
The publication of these standards is not a signal to wait and see — it is the starting gun for technical implementation. Three areas of action are immediately relevant:
1. Define your identifier strategy EN 18219 permits various identification schemes, as long as they meet the requirements for uniqueness and persistence. Companies that already use GS1 numbers can build on their existing system. If you are not yet using a standardized identification system, now is the time to decide.
2. Audit your data model against EN 18222 Existing product databases are rarely structured in a way that allows them to serve directly as a DPP data source. EN 18222 imposes requirements for semantic unambiguity that will break open internal data silo structures. A gap analysis against the standard is the logical first step.
3. Establish update processes for dynamic data If you place batteries or other products with variable condition data on the market, you need an operational process that automatically updates data points such as SoH or repair history. This is not purely an IT question — it requires interfaces with repair shops, recycling companies, and logistics providers.
The harmonized standards EN 18219, EN 18220, and EN 18222 are technical standards, not marketing documents. They define precisely what a compliant DPP must deliver — and for the first time make it bindingly measurable what was previously open to interpretation. For industry, this is both a challenge and an opportunity: those who implement early avoid the compliance scramble right before the deadline.
