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Alpha: Odal Node is in active development. APIs, schemas and docs will change before 1.0.

Acts and standards

This is the reference behind the website’s regulations page: every EU act and standard the code cites, grouped by what the software does with it, with the articles it relies on, and then the acts it does not apply yet but is preparing for.

These are records in the core library’s instrument catalog, and the website’s regulations page is generated from them, with dates and where each date comes from.

Act Passport provision the catalog rests on
Batteries Regulation (EU) 2023/1542 Art. 77(1), from 18 February 2027; access by Art. 77(2) and Annex XIII
Ecodesign for Sustainable Products Regulation (EU) 2024/1781 Art. 9(1), dated act by act through delegated acts; access by Art. 11(b)
Construction Products Regulation (EU) 2024/3110 Art. 22(7): 18 months after the Art. 75(1) delegated act, not yet adopted
Detergents Regulation (EU) 2026/405 Art. 21(1), applying from 23 September 2029 (Art. 37); transition in Art. 36(2)
Toy Safety Regulation (EU) 2025/2509 Art. 19(1), applying from 1 August 2030 (Art. 59)
End-of-Life Vehicles Regulation (EU) 2026/1738 Art. 13(1): a vehicle passport from 1 September 2032
Delegated Regulation (EU) 2026/296 and Implementing Regulation (EU) 2026/2 No passport: the unsold-goods destruction derogations and disclosure format
Regulations (EU) 2023/1670 and 2023/1669 No passport: product information goes to EPREL
Packaging and Packaging Waste Regulation (EU) 2025/40 No passport: a shared data carrier only
Act Relied on for What the code does
eIDAS, Regulation (EU) No 910/2014 as amended Art. 3(27) qualified seal; Art. 22 trusted lists; Art. 32 applied to seals by Art. 40; Art. 42 qualified time stamps Seals published passports (its local sealer makes full long-term seals, marked as not qualified) and reports whether a seal is qualified; until the operator’s company holds a qualified certificate, every seal says it is not, and so carries none of the Art. 35(2) presumptions
Implementing Regulation (EU) 2026/248 Annex I reference formats; Annex II formats lawful until February 2028 Makes seals in CAdES (ETSI EN 319 122-1); JAdES headers carry the certificate chain (x5c)
Implementing Regulation (EU) 2025/1945 Validation of qualified seals, including revocation freshness The seal audit reports in ETSI EN 319 102-1 terms, and treats “cannot be read” as its own result, not a failure
Implementing Decision (EU) 2015/1505, as amended by (EU) 2025/2164 Annex I trusted-list signature profile Reads and verifies the EU trusted lists to check who issued a seal’s certificate
Act Relied on for What the code does
Implementing Regulation (EU) 2026/1778 Art. 8(3) granularity; Art. 8(7)(c)–(d) fields the registry checks; Art. 9(2)(a) proof of registration; commodity codes Models registration and the identifiers the registry checks; registering for real needs the operator’s legal identity, and the live connection is not finished yet
Implementing Decision (EU) 2026/1736, with ESPR Art. 41(2) The six harmonised passport standards and their presumption of conformity Identifiers follow EN 18219, in three of its schemes, and earlier passport versions are kept as EN 18221 describes; see Harmonised standards
Act Relied on for What the code does
Market Surveillance Regulation (EU) 2019/1020 Art. 4(4) operator contact details; Art. 4(5) product scope Records the responsible economic operator in the EU and the basis they are named under, as ESPR Annex III(k) requires
General Product Safety Regulation (EU) 2023/988 Art. 15, as ESPR Annex III(k) cites it (the responsible-person provision itself is Art. 16) An alternative basis for the same record; a third is “similar tasks pursuant to other Union law”
Act Relied on for What the code does
REACH, Regulation (EC) No 1907/2006 Art. 33(1), the 0.1 % w/w threshold Records substances of very high concern and checks declarations against a compiled part of the candidate list (32 substances), flagging that the list is partial
RoHS Directive 2011/65/EU Annex II restricted substances The phone and tablet record notes compliance
Act Relied on for What the code does
Tyre Labelling Regulation (EU) 2020/740 Annex I label classes; Part C noise bands against the Regulation (EC) No 661/2009 limits Tyre passports carry fuel efficiency, wet grip and noise classes
Energy Labelling Regulation (EU) 2017/1369 Art. 12, the EPREL product database The phone and tablet record carries the energy class; EPREL is the system that displaces a passport for them
Critical Raw Materials Act (EU) 2024/1252 The list of critical raw materials Battery passports and the phone and tablet record list the ones a product contains
Act Relied on for What the code does
Combined Nomenclature, Regulation (EEC) No 2658/87 Annex I product codes, as Implementing Regulation (EU) 2026/2 Art. 3 requires Groups discarded products by CN code
Waste Framework Directive 2008/98/EC Art. 3(15)–(19): recovery, preparing for reuse, recycling, disposal Treatment categories in the unsold-goods disclosure; a product’s waste status at end of life
Company Law Directive (EU) 2017/1132 The European unique identifier (EUID) Identifies the undertaking in the unsold-goods disclosure

The code applies none of these today. Each binds a product group the software models, a feature on the roadmap, or the software itself. Drafts and proposals are listed as they stand on EUR-Lex and may change before adoption.

Act Status Why it is here
Draft Delegated Regulation on the carbon footprint of electric vehicle batteries, Ares(2024)3131389 Draft, under Batteries Regulation Art. 7(1), fourth subparagraph, point (a) The calculation method behind the carbon footprint a battery passport carries. The software calculates no battery carbon footprint before it is adopted
Draft Implementing Regulation on the format of the carbon footprint declaration, Ares(2024)3131449 Draft, under Art. 7(1), fourth subparagraph, point (b) The declaration format that goes with the method
Commission proposal COM(2025) 504, amending Regulations (EU) 2023/1542, (EU) 2024/1781 and others as regards digitalisation and common specifications Proposal, procedure 2025/0134(COD) Where other Union law requires a digital product passport, the EU declaration of conformity and the instructions would be provided in it
Implementing Regulation (EU) 2025/1943 In force Annex II: the reference standards for qualified certificates for electronic seals, including ETSI EN 319 412-3. A seal can be qualified only with such a certificate
Implementing Decision (EU) 2016/650 In force Security assessment standards for qualified seal creation devices, for qualified seals and for keys held in hardware
Deforestation Regulation (EU) 2023/1115 In force Annex I covers new pneumatic tyres of rubber (ex 4011), and Art. 4(2) requires a due diligence statement before they are placed on the market. The tyre product group does not record it
Cyber Resilience Act, Regulation (EU) 2024/2847 In force; Art. 14 reporting applies from 11 September 2026 and the rest from 11 December 2027 (Art. 71(2)) Cybersecurity requirements for products with digital elements. It concerns the software itself, not passport content

Guidance is not law, but the code follows these documents where the acts leave the detail open, so the version matters.

  • Digital Product Passport Registry User Guide, version 1.02 (24 August 2026). The identifier and field rules of the registry model.
  • Digital battery passport data points by category. The battery rules follow version 1.0 (28 July 2026). Version 2.0 (15 August 2026) is current and is not yet reflected in them.
  • Ecodesign for Sustainable Products and Energy Labelling Working Plan 2025-2030, COM(2025) 187. The order and indicative years of the product groups still to come.
  • Carbon Border Adjustment Mechanism, Regulation (EU) 2023/956. The steel and aluminium checks use reference carbon values as warnings only. CBAM sets no per-product limit a passport is checked against.
  • Accounting Directive 2013/34/EU, Arts. 19a and 29a. Implementing Regulation (EU) 2026/2 Art. 2(2) lets an undertaking point its unsold-goods disclosure at its sustainability reporting instead. The software does not model that route yet.
  • Earlier acts being replaced. Each is still in force while the act replacing it takes over in stages: Directive 2006/66/EC (batteries, by Regulation (EU) 2023/1542), Directive 2009/48/EC (toys, by Regulation (EU) 2025/2509), Regulation (EC) No 648/2004 (detergents, by Regulation (EU) 2026/405), Regulation (EU) No 305/2011 (construction, by Regulation (EU) 2024/3110), Directive 2009/125/EC (ecodesign, by Regulation (EU) 2024/1781) and Directive 2000/53/EC (end-of-life vehicles, by Regulation (EU) 2026/1738).
  • Repealed acts, cited so the history reads correctly: Regulation (EC) No 1222/2009 (tyre labels) and Directive 1999/93/EC (electronic signatures).

The standards the code relies on, and what each is used for, are on Standards & interoperability.