Separate publication from implementation evidence
BSI lists BS EN 18220:2026 as current, published on 31 May 2026. Its public scope concerns DPP carriers, their production and readability, durability, recognisability and the physical-to-digital relationship.
EN 18220:2026 is entry 3 in the Annex to Decision (EU) 2026/1736, published on 15 July 2026. ESPR Article 41(2) limits the presumption of conformity to covered requirements. An organisation still needs evidence for its actual implementation. The full standard was not available for preparing this guide.
Source: BSI: BS EN 18220:2026, publication status and public scopeSource: European Commission: harmonised standards for Digital Product PassportsSource: Commission Implementing Decision (EU) 2026/1736, Article 1 and AnnexSource: Regulation (EU) 2024/1781: Articles 9–11 and 41
Start with the product and its permitted carrier
First establish which product rules apply and what they say about carrier type and placement. The battery passport provisions expressly refer to QR access. A different symbology is not automatically permissible because a supplier can print it more cheaply or a warehouse scanner already supports it.
Next describe the use: who scans the code, where the product will be, what lighting is likely and whether packaging remains with it. For an operational pilot, compare realistic options against those conditions. Keep the legal decision separate from convenience decisions about label suppliers or print equipment.
Source: Regulation (EU) 2024/1781: Articles 9–11 and 41Source: Regulation (EU) 2023/1542: Articles 13 and 77
Turn the artwork into a controlled production specification
Our recommended production record includes the approved payload, symbol generation settings, intended dimensions, stock, printing process and attachment location. Identify which file is authoritative. Prevent a packaging supplier from recreating the code by copying a screenshot into a layout and assuming it is equivalent.
Review the final assembled artwork, including neighbouring text, finishing and folds. A good standalone symbol can become difficult to read after varnish, scaling or trimming. Send a physical reference sample through approval and explain which changes require another review. These are production-control recommendations, not unverified clauses or quality grades attributed to the standard.
Design a test plan around credible failure modes
Choose a manageable set of representative samples and state why it reflects the intended use. Combine freshly produced labels with relevant handling scenarios. Test the actual placement rather than a convenient flat substitute. Document reader types, conditions, attempts and the decoded result so another person can repeat the assessment.
Separate a software round-trip test from a physical quality assessment. The first checks the generated file; the second examines what was printed or marked. Neither should be described as a comprehensive norm assessment unless its coverage has actually been established against the complete applicable documents.
- Confirm that the decoded payload matches the released version.
- Check that the carrier still identifies the product after unpacking or relabelling.
- Record problems caused by surface, curvature or finishing rather than hiding them in an average.
- Have a named reviewer decide whether the evidence supports release.
Verify the destination after the physical scan
A carrier pilot should test the entire user journey. After scanning, verify the product identity, the available information and the behaviour when a record is revised or temporarily unavailable. A perfectly readable label that opens the wrong model is a failure even if the decoder reports success.
Review access independently from physical recognition. A visible product code should not be treated as a secret authorisation credential. Decide how public information and restricted service information are presented. Test with separate user contexts rather than relying on an administrator’s already-authenticated browser.
Make release and maintenance responsibilities explicit
Assign ownership of the artwork, printer profile, physical verification, resolver destination and change approval. Keep the approved evidence with the production decision so a replacement supplier can understand what must be preserved. Revisit affected checks after a change in stock, printer, carrier content or product placement.
Passvanta can support the prepared product record and carrier-generation workflow, including software decoding and print geometry. Use those outputs in your acceptance package alongside physical evidence. This does not assert that all EN 18220 clauses, product-specific requirements or EU registry checks have been passed.
Sources and supporting material
- Regulation (EU) 2024/1781: Articles 9–11 and 41
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- Regulation (EU) 2023/1542: Articles 13 and 77
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- BSI: BS EN 18220:2026, publication status and public scope
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- European Commission: harmonised standards for Digital Product Passports
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- Commission Implementing Decision (EU) 2026/1736, Article 1 and Annex
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