EN 18219: unique identifiers for digital product passports

EN 18219 is the European standard for the identifiers a digital product passport is built on: the identifier of the product, of the economic operator and of the facility. It is written for manufacturers, brands, importers and passport service providers who have to give each product an address that lasts. It matters because ESPR requires every product passport to be connected to a persistent unique product identifier, and since July 2026 EN 18219 is a harmonised standard for exactly that.

The standard was drafted by CEN-CLC/JTC 24 under the Commission's standardisation request M/604, approved by CEN on 3 May 2026 and adopted by SIS as SS-EN 18219:2026 on 27 May 2026 (62 pages). The full text is sold, not free. This article relies on what is public: the standard's scope, the legal text and CEN-CENELEC's own presentation, plus the clauses we have read ourselves and base our validator on.

What the standard covers

According to its scope, EN 18219 defines the principles and specifies requirements and guidelines for three kinds of identifier used in digital product passports:

• the unique product identifier, which points to the product and leads to the passport;
• the unique economic operator identifier, for the manufacturer, importer and other actors;
• the unique facility identifier, for locations and buildings in the value chain.

It covers six areas: global uniqueness, persistence, syntax, granularity, interoperability and openness. It accommodates product identifiers at three levels of granularity: model, batch or individual item. And it describes identification schemes that use issuing agencies, self-issuing systems, or a combination of both.

At the CEN-CENELEC webinar on 25 June 2026, the working group summed the standard up as "No proper ID = No trusted DPP". The same slide lists the general requirements: an identifier is globally unique, persistent, machine-readable, usable across systems and has a stated level of granularity. It also shows the split: five identification schemes for products, and four for economic operators and facilities. The working group (JTC 24/WG 2) drafted EN 18219 and EN 18220 together over a year and a half.

What it requires in practice

An identifier that works as a web address

ESPR defines a unique product identifier as a unique string of characters that identifies a product and also enables a web link to the digital product passport. EN 18219 follows the same line: under §4.3.2 the product identifier is a URL or can be converted into one. In practice that means an address a phone camera can open, not an internal article number.

Five schemes to choose from

Clause 5 holds the five identification schemes for products, and §5.1 requires a unique product identifier to follow one of them. In short:

1. Web-enabled structured path or query (§5.2). Built on GS1 Application Identifiers or ASC MH10.8.2 Data Identifiers, with an issuing agency code registered under ISO/IEC 15459-2. GS1 Digital Link belongs here, for example /01/<GTIN>/21/<serial>.
2. Identification Link under EN IEC 61406 (§5.3). Self-issued: no issuing agency code and no membership. With Part 1 alone it identifies an item; models and batches need Part 2 with ASC MH10.8.2 Data Identifiers. Uniqueness comes from a web domain the economic operator controls. See the article on IEC 61406.
3. Decentralised identifiers (§5.4) under W3C DID Core 1.0, such as did:web.
4. Identification for products and product groups (§5.5), for limited-capacity carriers such as RAIN RFID and 2D codes, under ISO/IEC 15459-4 and -6 with a registered issuing agency code. The identifier is encoded in the tag or code and reached as a web address through a resolver.
5. DOI under ISO 26324 (§5.6). The publisher declares whether the DOI identifies a model, batch or item, and the address begins with lowercase doi.org.

The existence of five schemes is the point. The standard does not require GS1, even though GS1 Digital Link is the route many take because the same GTIN is already used at the till.

Granularity that holds over time

The level of the passport is set by the delegated act for the product group (ESPR Article 9(2)(d)). EN 18219 governs what happens when that level has to change. Under §4.4.2(3), if a change in granularity cannot be accommodated with the existing identifier, a new or extended unique product identifier shall be assigned, and it shall be linked to the old one to maintain traceability. The typical case is a brand moving from model-level passports to passports per batch or per item.

Modelone identifier for every unit

Batchone identifier per batch

Itemone identifier per unit

Old identifierNew or extended identifierwhen a change of level cannot be held by the old one, linked to it (§4.4.2(3))

Operators and facilities

Clause 6 holds the schemes for economic operator and facility identifiers. ESPR Article 12 requires those identifiers to comply with the standards in Annex III, or equivalent ones, until references to harmonised standards are published in the Official Journal. They now have been. A free-text company name is therefore not an identifier in the standard's sense.

How it relates to the other standards and the law

EN 18219 is one of six standards listed in Commission Implementing Decision (EU) 2026/1736, dated 14 July 2026 and published in the Official Journal, and in force, on 15 July 2026. Under ESPR Article 41(2), a passport that conforms to such a standard is presumed to meet the requirements of Articles 10 and 11 to the extent the standard covers them.

The link to the regulation is Article 10(1): the passport shall be connected through a data carrier to a persistent unique product identifier (a); the data carrier shall be physically present on the product, its packaging or accompanying documentation (b); and the carrier and identifier shall comply with the standards in Annex III, or equivalent ones, until harmonised standards are published (c). Annex III names ISO/IEC 15459-1 to -6, which has its own article.

Within the series, EN 18219 is the key the others hang from:

• EN 18220 sets how the identifier is carried on the product, for example in a QR code.
• EN 18222 defines API methods that fetch a passport by product identifier.
• EN 18223 puts the product identifier and the granularity in the passport header.
• EN 18221 keeps the passport available, without which a persistent identifier leads nowhere.

The Commission's passport registry (ESPR Article 13) stores at least the unique identifiers. Its arrangements are set out in Implementing Regulation (EU) 2026/1778 of 16 July 2026.

Batteries fall under Regulation (EU) 2023/1542. Article 77(3) requires the QR code and the unique identifier to comply with ISO/IEC 15459-1 to -6 or their equivalent. The Commission may change the reference by delegated act; until then the wording of the regulation applies.

Common misunderstandings

"EN 18219 requires GS1"

It does not. GS1 Digital Link is one of five schemes. An Identification Link, a DID or a DOI can also be a valid product identifier, as long as that scheme's own requirements are met.

"The identifier is the passport"

The identifier points to the product and leads to the passport. The passport has an identity of its own, and EN 18223 keeps the passport identifier and the product identifier apart.

"Every product needs an item-level passport"

The standard allows model, batch and item. Which level is required is set by the delegated act for the product group, or by the Batteries Regulation. For batteries in scope of Article 77, the passport is per battery.

"A new passport can replace the old one without a trace"

EN 18219 (on a change of granularity) and ESPR Article 11(d) (when a new passport is created for a product that already has one) both require the new one to be linked to the original. Batteries Regulation Article 77(7) requires the same for batteries prepared for re-use or repurposed.

"Any web address will do"

For self-issued identifiers, uniqueness comes from the domain, and the domain has to be one the economic operator controls. An address that changes hands or disappears does not meet the persistence requirement.

How this looks in practice

DPP Agent, built by Blippa, addresses every passport as a GS1 Digital Link where a valid GTIN exists, for example lindex.dpp.dppagent.com/01/07314781685466/21/002: GTIN plus serial number, so one passport per item. For a brand's own passports we propose its own domain, such as dpp.brand.com. Our validator at dppagent.com/validate reads which of the five schemes an identifier follows, and does not fail an address for not being GS1.