A supplier sends you a spreadsheet of product data. One column is called “capacity”. Is that a number in ampere-hours or in kilowatt-hours? The rated value or a measured one? The spreadsheet does not say. Whoever knows the supplier can tell from context. Everyone else guesses.
The fix is a dictionary: a list that says what “capacity” means, which unit it comes in and what kind of value is allowed. If anyone can open that dictionary, a note in the column header is enough: capacity as per entry 4711. If the dictionary costs money or is not public, the note is useless to the recipient. Then the sender has to write the meaning into every cell: which dictionary, which entry, which unit, which type, and only then the value.
That is the core of EN 18223, the standard that defines how Digital Product Passports carry their meaning. This article explains what the standard asks of your data, why its spelled-out form is so long, and why for Transpareo customers it is an output format rather than a project.
Two ways of writing, one content
EN 18223 is the standard of the European standardisation committee CEN/CLC JTC 24 on the interoperability of Digital Product Passports. It describes a data model and two ways of writing it down.
The compressed form is the shorthand for operation. Each value sits under its identifier, the elementId, and the reader looks up what is behind it in the dictionary. Three lines per value.
The expanded form spells everything out. Each value becomes a small object with identifier, dictionary reference, object type, data type and the value itself. Three lines become twenty.
Why the long form is so long
The length is not an oversight. It is what meaning looks like once you cannot assume the reader can look it up.
A product passport normally carries meaning through a link: the reader follows it and sees what a field means. That works as long as the link leads somewhere open.
Two of the most widely used dictionaries for industrial product data, ECLASS and IEC CDD, are paid. A link to them is worth nothing to a reader without a licence. So the expanded form asks that the meaning travel inside the document, value by value: which dictionary, which entry, which type, which value. The document explains itself, even when nobody can click through.
Read that way, the length is a sensible response to closed dictionaries, not a design failure.
The dictionaries Transpareo builds on, the OpenEPCIS DPP Core and its extensions per regulation, are published openly at ref.openepcis.io. Anyone can look them up. There, a single link carries what a closed dictionary has to spell out.
The direction decides
Back to the spreadsheet. Whoever labelled the columns with the open dictionary from the start can produce the spelled-out version at any time: look up the meaning, write it next to the value, done. Whoever holds the meaning only in a closed dictionary, or not at all, has to reconstruct it first. That is the expensive direction.
Our data already carries every attribute the EN 18223 model asks for: a reference to the property, one to the dictionary, the data type, the language of every value. They just sit in our own arrangement, with links to open dictionaries, instead of in the standard’s.
Producing the standard’s form from that is a formatting exercise: take the fields that already exist and lay them out in the target shape.
In one sentence: a source with open dictionaries turns every closed dictionary into a view it produces on demand. Only whoever started closed pays for the standard’s length.
Several dictionaries side by side
That our data has this shape is a deliberate choice. We do not force every regulation into a single vocabulary.
Each EU DPP regulation, whether battery, textile, electronics or the ones still to come, keeps its own dictionary: GS1’s, the OpenEPCIS DPP Core’s, the regulation’s own. All of them sit side by side, joined by a deliberately small dictionary of our own for the handful of terms none of them covers.
EN 18223 asks for almost exactly this in its introduction: do not force a single dictionary on every sector, allow the dictionaries of the individual legal acts to sit side by side, keep the shared part as general as possible. An architecture built on open, parallel dictionaries is therefore not merely compatible with the standard. It is what the standard itself points to.
A stress test: the Battery Pass attribute list
Whether that holds shows in a dictionary the architecture was never built for.
The Battery Pass Consortium’s Data Attribute Long List, version 1.3, is a third dictionary that diverges from both EN 18223 and GS1: about 100 attributes, its own names, its own access tiers, a consortium’s reading of Annex XIII of the Battery Regulation.
We matched it against our existing data model. 91 of the 100 attributes fitted existing property types unchanged. A new closed dictionary is added as one more view and forces no rebuild.
Where the standard stands
EN 18223 and its sibling EN 18216, which defines the concrete wire format EN 18223 defers to, are both harmonised European Standards.
They belong to the first published wave of the CEN/CLC JTC 24 DPP set: six of the eight standards, with the remaining two, on authentication and access rights, not cited yet. Those six were cited in the EU Official Journal on 15 July 2026 by Commission Implementing Decision (EU) 2026/1736. That confers harmonised status and, with it, the presumption of conformity with Articles 10 and 11 of the ESPR.
What this means for you
None of this makes EN 18223 the wrong standard. Its length is the honest price of interoperability in a world where not every dictionary is open, and the standard handles that world well.
For Transpareo customers it stays simple: the standard is an output format the platform produces on demand. No rebuild, no project. The meaning of your data is open from the first save, and everything after that is formatting.
Questions on this article
Is EN 18223 mandatory?
No. It is a harmonised European Standard, which gives a presumption of conformity rather than an obligation. EN 18223 and five sibling standards were cited in the EU Official Journal on 15 July 2026 by Commission Implementing Decision (EU) 2026/1736, so following them means you are presumed to meet Articles 10 and 11 of the ESPR. You may satisfy those articles another way, and then you have to show it yourself.
Which of the two forms do we have to produce?
Both have their job. The compressed form is the shorthand for operation; it uses each value’s identifier as the key and leaves the dictionary reference and the data type to be looked up. The expanded form spells everything out, so each value becomes an object with its own identifier, dictionary reference, object type, data type and value. Which one you emit depends on whether the reader can open your dictionary.
Do we need an ECLASS or IEC CDD licence?
Not for the route described here. Those two dictionaries are paid and not public, which is exactly why the expanded form has to spell out the meaning value by value. The dictionaries Transpareo builds on are published openly and anyone can look them up, so a single link carries what a closed dictionary would have to spell out.
Why is the expanded form so long?
Because that is what meaning looks like once you can no longer assume the reader can look it up. A product passport normally carries meaning through a link the reader follows to look up what a field means. When the dictionary behind a field is paywalled, that link is worth nothing to the reader, so the meaning has to travel inside the document instead. Read that way, the length is a sensible response to closed dictionaries, not a design failure.
What changes for us if our data already points to open dictionaries?
It becomes a formatting exercise. Such data already carries every attribute the model asks for, a property reference, a dictionary reference, a data type and the language of every value, just in its own arrangement instead of the standard’s. Producing the standard’s form from it means laying existing fields out in the target shape, not running a migration project.
How many of the DPP standards are published?
Six of the eight standards in the CEN-CENELEC JTC 24 set were in the first published wave and were cited in the Official Journal on 15 July 2026. The remaining two, on authentication and access rights, have not been cited yet. EN 18216, the sibling that defines the concrete wire format EN 18223 defers to, is among the published six.
Does a new dictionary force us to redesign the data model?
Not when the source carries several dictionaries side by side. We tested that against the Battery Pass Consortium’s Data Attribute Long List, version 1.3, a third dictionary with its own naming and its own access tiers that diverges from both EN 18223 and GS1. 91 of its 100 attributes fitted property types that already existed, unchanged. A new closed dictionary is taken in as one more view.
Does conforming to EN 18223 mean our passports are registered?
No, those are two different things. Conformity concerns the shape and meaning of the passport; registration is a separate act in the EU DPP register, operational since 20 July 2026 under Implementing Regulation (EU) 2026/1778 and with its technical interface still being specified. Only the economic operator placing the product on the market may register, so a service provider cannot do it for you. Transpareo prepares what the entry asks for, the product identifier, the passport address and the fingerprint. More in our analysis of the register regulation.
