regulations

Six DPP standards gain presumption of conformity

What the Official Journal publication of six DPP standards on 15 July 2026 changes for ESPR implementation.

7/16/2026 · 6 min read · InfoDPP

Six DPP standard references are now in the Official Journal

On 15 July 2026, the Commission published Implementing Decision (EU) 2026/1736. The Decision lists six harmonised standards for digital product passports (DPPs) drafted in support of the ESPR, Regulation (EU) 2024/1781.

CEN/CENELEC published the EN standards in May 2026. Decision 2026/1736 then published references to those standards in the Official Journal. Publication of the references provides the basis for the presumption of conformity under ESPR Article 41(2).

Standards covered by the Decision

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 product-passport lifecycle management and searchability;
EN 18223:2026: system interoperability.

These standards cover the common technical infrastructure for DPPs: identifiers, carriers, data, APIs and system interoperability. They do not by themselves set every sector’s complete data set.

What the presumption of conformity means

A DPP that conforms to one of these standards, or part of one, benefits from a presumption of conformity with ESPR Articles 10 and 11, but only to the extent that the standard covers those requirements. It helps demonstrate technical compliance; it is not a product certificate or automatic evidence of compliance with all EU law.

A company can choose a different technical solution, but must then demonstrate that it meets the legal requirements. Harmonised standards are voluntary. Using them makes conformity easier to demonstrate, but does not remove the requirements for the product category concerned.

What the Decision does not change

It does not create a DPP obligation for every product group; sectoral timing and data still come from the relevant delegated acts or sector-specific regulations.
It does not mean that every product carrying a QR code is ESPR-compliant.
It does not yet include the JTC 24 work on access rights, security, authentication and data integrity: FprEN 18239 and FprEN 18246.
It does not replace the separate battery-passport rules. Article 77 of the Batteries Regulation still governs its QR code and identifier, and changing the standards named there requires a separate delegated act.

A separate proposal changes the battery references

The 30 September webinar for batteries, slide 8, describes a draft delegated act that would update Article 77(3) to EN 18220:2026 for QR codes and EN 18219:2026 for unique identifiers, or equivalent standards. The presentation reports publication of the draft for feedback on 29 September and envisages adoption and publication in 2027. Those dates describe a proposal and a plan, not an amendment already in force.

The draft is part of an act on industrial battery performance and durability, but the proposed change concerns the identification provision for battery passports. It should not be read as a new passport obligation only for industrial batteries or as a change to every product passport. Article 77(3) currently refers to the ISO/IEC 15459 series or equivalent standards.

In battery specifications and supplier contracts, distinguish the standards referenced by the current rules from the references proposed in the draft amendment. The presumption of conformity under Decision (EU) 2026/1736 applies only to the ESPR requirements covered by those standards. The Decision does not amend the Batteries Regulation.

What companies should do now

Map current identifiers, data carriers, archiving, APIs and data export against the six standard areas.
Retain technical evidence and architecture decisions: the presumption follows actual conformity, not merely naming an EN number.
Avoid claims of “full DPP compliance” unless the relevant sectoral requirements and remaining technical elements are also covered.

Official sources

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