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Digital Product Passport data requirements and harmonised standards

Guide to Decision (EU) 2026/1736, the six harmonised DPP standards, and presumption of conformity under ESPR.

Verca editorial team•Guide•Published: 17 July 2026•Last fact-checked: 22 August 2026•3 min read

Short answer

On 14 July 2026, the European Commission adopted Implementing Decision (EU) 2026/1736. It was published in the Official Journal and entered into force on 15 July 2026. The Decision published the references of the first six harmonised standards for digital product passports under the Ecodesign for Sustainable Products Regulation, ESPR (EU) 2024/1781.

Key takeaways

  • Identify applicable legislation, product group, and market date
  • Map product-specific data fields and accountable data sources
  • Define granularity and the identifier model under EN 18219
  • Plan data exchange and carriers against EN 18216 and EN 18220
  • Assess storage, APIs, and interoperability against EN 18221–18223
  • Document standard editions, coverage, deviations, access, and data quality

This content is a practical overview, not legal advice. Always verify the current legislation and the requirements that apply to your product. Research uses official primary sources; competitor content is used only to identify questions and content gaps.

The standards define system architecture – not every product data field

Articles 10 and 11 of ESPR establish requirements for the DPP system and its technical design. Which products require a passport, which data fields are mandatory, and when the obligation applies are still determined by product-specific delegated acts or sector legislation. Decision (EU) 2026/1736 therefore does not make a DPP mandatory for every product.

The six standards cover the DPP system's technical chain

  • EN 18216:2026: data exchange protocols
  • EN 18219:2026: unique identifiers
  • EN 18220:2026: data carriers
  • EN 18221:2026: data storage, archiving, and persistence
  • EN 18222:2026: APIs for lifecycle management and searchability
  • EN 18223:2026: system interoperability

Together, the standards provide a technical reference for connecting identification, access, storage, and exchange into an interoperable product passport.

Presumption of conformity under ESPR Article 41(2)

A digital product passport that conforms to a cited harmonised standard is presumed to meet the requirements in Articles 10 and 11 of ESPR that the standard covers. The presumption therefore applies to the covered system requirements – not automatically to all of ESPR, the product's other sustainability requirements, or product-specific data requirements. Document the standard edition, applied scope, technical solution, deviations, and supplementary evidence.

Confusing system standards with a complete product passport obligation

The cited standards do not mean that every regulated product immediately requires a DPP or that identical data fields apply to every product group. Another common mistake is treating use of a standard as complete regulatory approval. Companies must still determine the applicable act, product group, mandatory data, access levels, and market date.

Prepare DPP architecture against the cited standards

  • Identify applicable legislation, product group, and market date
  • Map product-specific data fields and accountable data sources
  • Define granularity and the identifier model under EN 18219
  • Plan data exchange and carriers against EN 18216 and EN 18220
  • Assess storage, APIs, and interoperability against EN 18221–18223
  • Document standard editions, coverage, deviations, access, and data quality

Prepare traceable product data for the DPP architecture

Verca collects product, material, document, and supplier data that can be mapped to future product-specific DPP requirements. The harmonised standards now provide a clearer technical reference for continued development. Verca does not issue a universal DPP, certify conformity with the standards, or assume the economic operator's responsibility.

Frequently asked questions

What does this mean in practice?+

On 14 July 2026, the European Commission adopted Implementing Decision (EU) 2026/1736. It was published in the Official Journal and entered into force on 15 July 2026.

Who is responsible for the work?+

Articles 10 and 11 of ESPR establish requirements for the DPP system and its technical design. Which products require a passport, which data fields are mandatory, and when the obligation applies are still determined by product-specific delegated acts or sector legislation.

What documentation is required?+

A digital product passport that conforms to a cited harmonised standard is presumed to meet the requirements in Articles 10 and 11 of ESPR that the standard covers. The presumption therefore applies to the covered system requirements – not automatically to all of ESPR, the product's other sustainability requirements, or product-specific data requirements.

Official sources

Primary sources used for this guide.

  • Regulation (EU) 2024/1781 (ESPR), Opens on an external website
  • Implementing Decision (EU) 2026/1736, Opens on an external website

Continue exploring

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Digital Product Passport (DPP)

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Harmonised Standards and CE Marking

How harmonised standards provide presumption of conformity and how to document the correct edition.

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Technical Documentation and Technical File for CE Marking

What technical documentation should contain, how to structure it, and how long it must be retained.

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