Regulatory compliance

When you leave this page, you will know which European digital passport obligations weigh on your products today, which ones do not exist yet, and which dates are written into a legal text. You will also know, requirement by requirement, what SealTrust covers and what it does not.

#Two texts, two logics

Brands almost always ask us the same question: by what date do we have to be ready. The answer depends on which text concerns you, because the two main ones work in opposite ways.

#The ESPR sets a framework, then switches it on category by category

Regulation (EU) 2024/1781 on ecodesign for sustainable products, known as the ESPR, has been in force since July 18, 2024. It targets almost every physical product placed on the Union market, whatever the size of the company and its country of establishment.

It is a framework regulation. It creates the digital product passport, then switches it on product group by product group. Each group gets its own delegated act, generally with a transition period of about eighteen months. There is therefore no single switch-on date for the ESPR passport.

The consequence is direct. As long as the delegated act for your category is not adopted, no list of mandatory fields applies to you. No supplier can hand you the compliant list for textiles, electronics or construction today, because that list is not written yet.

#The battery regulation carries its date in its own text

Regulation (EU) 2023/1542 on batteries works differently. The passport obligation is written into article 77, with a firm date: the battery passport is required from February 18, 2027. The expected content is described in Annex XIII of the same regulation.

The scope covers three families: electric vehicle batteries, industrial batteries above 2 kWh, and light means of transport batteries, for example those of electric bikes and scooters. Portable batteries and starter batteries stay outside this scope.

It is also the only category whose passport level is known to date: each battery carries its own.

#The dates, firm and indicative

The table separates what is written in a legal text from what remains a forecast. The "Status" column is the only one that matters when arbitrating a budget.

The console renders six of these entries, without the row on the European registry. It picks them according to the passport template attached to your product model: a battery model displays the battery regulation, a textile model displays the textile delegated act and the ESPR framework, an electronics model displays the smartphone regulation and the EEE part of the ESPR. The state of the European registry is displayed elsewhere, in the "Readiness" tab.

#The passport level decides your budget

The ESPR provides, in its recital 33, that delegated acts examine the establishment of information requirements through a digital passport at the level of the model, the batch or the item. The level is therefore decided act by act, product family by product family.

Today, only batteries have a known level, and it is the item. For every other category, the level is not set.

This point drives your labeling bill. A model passport calls for one record per catalog reference. An item passport calls for a unique identifier per manufactured piece, so unit-level marking across the whole production run. The gap is counted in factors of one hundred or one thousand.

SealTrust attaches a passport either to a product model or to one specific item. The reference passport, attached to the model, is shared by every item of that model. The item passport carries the data specific to one unit, for example the state of health of a battery.

#Requirement by requirement, what SealTrust covers

#A unique identifier carried by a data carrier

The ESPR provides that the delegated act of each product group specifies one or more data carriers. Carrying both a QR code and a chip is therefore provided for by the text.

Every item created in SealTrust receives a public serial number of twelve characters, drawn at random. That number resolves at https://sealtrust.io/p/{serial}, where {serial} is the number itself. That is the address printed in the QR code.

The QR code alone is enough to identify a product and reach its passport. An NFC seal is added when you want a proof of originality carried by the chip itself. The battery passport template shipped with SealTrust declares the QR code as the carrier, which is what the battery regulation requires.

#Machine-readable data, in standardized vocabularies

The ESPR requires, in its article 10, paragraph 1, point (d), that the passport rely on standardized vocabularies.

SealTrust renders the passport in JSON-LD, with the Schema.org and GS1 Web Vocabulary vocabularies. You get this format by adding format=jsonld to the public read of an item.

curl "https://api.sealtrust.io/v1/passport/000000000000?format=jsonld"

const reponse = await fetch(
  "https://api.sealtrust.io/v1/passport/000000000000?format=jsonld"
);
const passeport = await reponse.json();
console.log(passeport["@context"]);

import requests

reponse = requests.get(
    "https://api.sealtrust.io/v1/passport/000000000000",
    params={"format": "jsonld"},
    timeout=30,
)
passeport = reponse.json()
print(passeport["@context"])

The rendered document declares three namespaces: https://schema.org/ by default, gs1 for https://gs1.org/voc/, and espr for https://data.europa.eu/espr/.

#Layered access, according to who is reading

The ESPR distinguishes several audiences: the public, consumers, value chain professionals, and market surveillance authorities. One and the same passport does not show the same fields to each of them.

SealTrust applies that distinction with six access tiers, asked for through the access_tier parameter:

The three professional tiers and the authority tier require authentication. An anonymous call that asks for one of them receives 401. An authenticated call without the matching accreditation receives 403.

The three professional tiers, repairer, recycler and upstream, are different audiences. None of them contains the others. Each of them inherits the public tier and the end user tier, then adds what its trade calls for, and nothing more: a repairer does not see the recycler's substances, a recycler does not see the manufacturing origin. That is the only property that makes need-to-know hold up.

upstream deserves a clarification, because it surprises people: no partner accreditation opens it. It is reserved for the accounts of the brand itself and for surveillance authorities. The two accreditations you can grant to a partner are repairer and recycler.

We provide default values. You can replace them with your own rules, section by section, in the "Access Rules" tab of the console. The full table of the fields served at each tier is in the guide Digital Product Passport.

#Substances of concern

The ESPR handles substances of concern in its article 7, paragraph 5. It calls for identifying them, saying where they sit in the product, at what concentration, and which safety instructions apply.

The console carries a "Substances" tab dedicated to these declarations. A declaration is attached to a product model, and optionally to one specific component. It accepts:

These declarations feed three outputs: the signed attestation of the passport, the JSON-LD export of the console, and the readiness score described further down. In those outputs they sit under the substances_of_concern section, served at the recycler, upstream and authority tiers, and closed at the open tiers.

#The European passport registry

The ESPR provides, in its articles 12 and 13, for a central European registry. That registry is an index. It does not host the data of your passports. It records the unique product identifier, called UPI, and the address at which the passport can be reached. It checks by itself that this address answers.

SealTrust builds that record for you. The UPI is the short address https://sealtrust.io/p/{serial}. The record also carries the GTIN of the model when it has one, the version of the passport, its hash, and the economic operator identifiers filled in on your brand.

Three constraints of the registry are already known: the UPI must be an https address, it must answer, and it must not exceed fifty characters. We check the length before any submission and we set aside from the file any record that is too long, because a single invalid record gets a whole file rejected.

You obtain that file today by asking SealTrust for it, with the list of items to include, designated by their serial number. No console screen produces it yet. The file comes with the list of the identifiers that were set aside, with the reason for each exclusion.

In the console, the "Readiness" tab displays the state of the connector to the registry. As long as sending is not switched on, the registration request returns the complete record we have built, without any network call. You see the content before it leaves.

#The battery passport in detail

The battery passport template shipped with SealTrust follows the categories of Annex XIII of Regulation (EU) 2023/1542. It applies to electric vehicle batteries, to industrial batteries above 2 kWh and to light means of transport batteries.

Two reading points matter for compliance.

The general specification is public. Annex XIII, part A, makes the general information of the battery accessible to everyone. The battery_specification section is therefore served from the public tier on. Without that, the public battery passport would hold none of its specification.

The state of health is restricted and specific to the unit. We serve those dynamic data at the repairer, recycler and authority tiers. They stay closed to the public and to the upstream tier. A state of health value only holds for one given physical battery, which matches the item level chosen by the regulation.

#What the console gives you to steer with

The console gathers DPP compliance in a single area, under "DPP Compliance", with seven tabs: Readiness, DPP Templates, Substances, Vocabulary, Access Rules, EPCIS and DPP Passports.

The "Readiness" tab computes a readiness score from 0 to 100 per product model. The score is spread over seven dimensions, with the following weights:

The "Evidence" dimension measures the actual coverage of your units. It counts five factors of equal weight: the share of items carrying a published passport, a signed attestation, a data hash, an IPFS copy and an active certificate of authenticity. It answers the first question an auditor asks: on how many pieces.

For the models attached to the battery or consumer electronics passport template, a sixth factor is added: the presence of at least one substance declaration, or the statement in the passport that no substance is present above the threshold. Either one is enough.

The console records the score over time, which traces a curve. A drop of more than five points against the previous measurement raises an alert.

Two exports go with the score. The evidence pack in PDF format exists for a product model and for your whole brand. The regulatory calendar takes up the six regulatory entries described above, picked according to the passport template attached to the product model.

#What SealTrust does not cover

This list is as important as the previous one.

• The passport at batch level. The text provides for three levels, SealTrust serves two, the model and the item.
• Filing with the European registry in your place. We produce the record and the file. Your company does the enrollment and the upload, with its own qualified electronic seal.
• A console screen for the filing file. No screen produces it yet. You ask SealTrust for it.
• The final mapping of the registry fields. The semantic catalog of the Commission is not published. Our record follows our own shape in the meantime.
• The registration of a reference passport with the registry. The registration path starts from the serial number of one unit.
• Returning substance declarations through the JSON read of the passport. They go through the signed attestation and through the JSON-LD export.
• A compliant list of fields for textiles, electronics or construction. Our passport templates for these categories are anticipatory. They take up data that these sectors already produce elsewhere. They cannot be compliant with a delegated act that does not exist.
• Legal advice. We describe legal texts and a product.

#Where to start

Four steps, in this order, whatever your category.

1. Determine whether a firm date concerns you. If you manufacture electric vehicle batteries, industrial batteries above 2 kWh or light means of transport batteries, your date is February 18, 2027 and your level is the item. In every other case, no passport date applies to you today.
2. Set the level of your passport. Model or item. That choice decides the marking to order, and it corrects badly once the production run is labeled.
3. Structure identity and data. A unique identifier per product, a durable data carrier, a composition and suppliers filled in per reference. That work stays valid whatever the delegated act that will come.
4. Measure. Publish a passport on one reference, look at the readiness score, deal with the gaps it names, and export the evidence pack.

#What to remember

• The ESPR has been in force since July 18, 2024, and it switches on category by category. No single passport date exists.
• The battery regulation carries a firm date in its own text: February 18, 2027, for electric vehicle batteries, industrial batteries above 2 kWh and light means of transport batteries.
• The delegated act of each family decides the passport level, model, batch or item. Only batteries have a known level today.
• SealTrust covers the unique identifier, the data carrier, the JSON-LD render, layered access, substance declarations and the building of the record for the European registry.
• SealTrust does not serve the batch level, does not file with the registry in your place, and cannot deliver a compliant list of fields for a category whose delegated act is not published.