DPP Standards and the Presumption of Conformity
A Digital Product Passport (DPP) has to be interoperable, so its technical details rest on standards. This article explains what harmonised standards for DPP are, how the presumption of conformity works, and why it is a practical tool for companies.
Why standards matter in a DPP
For passports from different manufacturers to be read in the same systems, common technical rules are needed. Standards define, among other things, how to encode identifiers, how the data carrier works, and how to structure data.
Without such standards, everyone would build a passport their own way, and interoperability would be a fiction. Standards are therefore the foundation on which the whole system rests.
The standards series for DPP
A horizontal series of harmonised standards is being developed for DPP — referred to as the EN 182xx series. It covers matters common to different sectors, such as identifiers and data carriers.
These standards are prepared by the European standardisation organisations. They emerge in stages, and individual documents in the series address different parts of the system. In this article we refer to the series as a whole, without spelling out individual numbers, because those are the subject of ongoing work.
What the presumption of conformity is
The presumption of conformity is a mechanism familiar from the EU's "New Approach" to product legislation. It works simply: if a product meets the relevant harmonised standard, it is presumed to meet the associated legal requirements.
For a company this is a practical simplification. Instead of proving conformity in many ways, you can rely on a recognised standard and benefit from the presumption. This lowers risk and streamlines the process of demonstrating conformity.
Why it matters for companies
The presumption of conformity turns standards from optional good practice into a real risk-management tool. By applying a standard, you gain a clearer path to showing that your passport meets the requirements.
It is worth remembering, though, that standards are usually voluntary — they are not the only route to conformity, but the safest and best-recognised one. We discuss ESPR's technology neutrality in Is GS1 mandatory.
When standards are not ready: common specifications
Developing a standard takes time — usually measured in years. To avoid a gap when the rules already apply but the standard is not ready, the EU has provided a fallback: common specifications.
These are technical requirements the Commission can adopt by an implementing act as a substitute. They act as a temporary bridge until harmonised standards exist. They are part of broader EU simplification efforts.
A practical approach
You do not have to track every standard number, but it is worth building your passport on recognised technical standards and interoperable formats. That way, when standards settle, your data will already be close to them.
The practical lesson is this: design for interoperability, and treat the presumption of conformity as a convenience worth using. We describe the role of identifiers in The three pillars of a DPP.
Standards and delegated acts
Standards do not work in a vacuum — they complement the rules. ESPR and delegated acts set out what a passport must contain, while technical standards say how to do it in an interoperable way. These are two different levels, worth keeping apart.
Meeting a standard does not replace the legal requirements, but it makes them easier to demonstrate thanks to the presumption of conformity. That is why it is best to read standards and delegated acts together: one sets the goal, the other provides a proven route to it.
Who develops DPP standards
Harmonised standards are produced by the European standardisation organisations, at the European Commission's request. It is a process based on consensus among experts from different countries and industries, which is why it usually takes years.
This slowness is the price of broad agreement and stability. For companies it means it is worth tracking the direction of the work, but you need not wait to organise your data until every document is published.
Common misconceptions about standards
A few myths circulate around standards and the presumption of conformity:
- that a standard is mandatory — it is usually voluntary but very helpful,
- that meeting a standard is the only way to show conformity — it is not,
- that common specifications are the end goal — they are a fallback,
- that you must know the standard's number to start — building interoperably is enough.
Distinguishing these helps you approach standards calmly and practically.
Key takeaways
- Standards ensure DPP interoperability — common rules for encoding identifiers, carriers and data.
- A horizontal EN 182xx series is being developed for DPP, emerging in stages.
- The presumption of conformity means meeting a standard = presumed to meet the legal requirements.
- Standards are usually voluntary but offer the safest path to demonstrating conformity.
- When standards are not ready, common specifications act as a temporary fallback.
See how CyfroPass builds passports on interoperable technical standards. Visit cyfropass.pl and create passports ready for DPP standards.