What Machine-Readable Means Under ESPR
ESPR Article 8 requires that the Digital Product Passport be accessible via a data carrier that complies with open standards and is interoperable. "Machine-readable" means that the DPP data can be parsed and processed by software without human intervention. This rules out PDF documents, images of text, and proprietary data formats that require licensed software to read. The DPP must be structured data — specifically, data formatted according to a published, openly accessible standard that any software developer can implement.
The EU Commission's DPP technical specification (published under ESPR Article 13) specifies JSON-LD as the primary machine-readable format for DPP data. JSON-LD (JavaScript Object Notation for Linked Data) is a W3C standard that combines the simplicity of JSON with the semantic richness of linked data. It is the same format used by Google, Bing, and other search engines for structured data markup — which means DPP data in JSON-LD format is directly compatible with existing web infrastructure.
Required Format Characteristics
| Requirement | Standard | Rationale |
|---|---|---|
| Open standard | W3C JSON-LD 1.1 | No licensing fees, publicly available specification |
| Interoperable | ISO/IEC 18975 (GS1 Digital Link) | Compatible with all GS1-compliant systems globally |
| Persistent identifier | GS1 GTIN + serial number | Stable identifier throughout product lifetime |
| Resolver protocol | GS1 Digital Link resolver | Single URL resolves to multiple data endpoints |
| API format | REST API with JSON responses | Standard web API format, widely supported |
| Vocabulary | Schema.org + EU DPP ontology | Shared vocabulary for semantic interoperability |
JSON-LD Structure for DPP Data
A DPP data record in JSON-LD format begins with a context declaration that maps property names to their semantic definitions. The EU DPP ontology defines the specific properties required for each product category. A minimal DPP JSON-LD record for a consumer electronics product includes: the product identifier (GTIN), the product model name, the manufacturer identity, the carbon footprint value, the recycled content percentage, the repairability score, and the EU Declaration of Conformity URL.
The JSON-LD format supports nested objects, which allows complex data structures to be represented in a single document. For example, the "manufacturer" property in a DPP record is itself an object containing the manufacturer's name, address, country, and EU Authorised Representative details. This nested structure allows all DPP data to be contained in a single JSON-LD document, which can be served from a single URL.
Data Carrier URL Structure
The data carrier (QR code) on a product encodes a GS1 Digital Link URL. When scanned, this URL resolves to the DPP data record. The URL structure follows the GS1 Digital Link syntax: https://[resolver-domain]/01/[GTIN]/21/[serial-number]. The resolver returns the DPP data in JSON-LD format when accessed by a machine (HTTP Accept header: application/ld+json) and returns a human-readable HTML page when accessed by a browser.
Context-Dependent Data Access
ESPR Article 8(4) requires that different actors can access different subsets of DPP data. Consumers see sustainability information and repairability data. Recyclers see material composition and disassembly instructions. Market surveillance authorities see the full technical file including the EU Declaration of Conformity. This context-dependent access is implemented through the GS1 Digital Link resolver, which returns different data subsets based on the identity and authorisation level of the requesting party.
Interoperability Requirements
ESPR Article 8(2)(b) requires that the data carrier "complies with open standards and is interoperable." This means that DPP data must be accessible to any compliant software system, not just the manufacturer's own systems or a specific third-party platform. The EU DPP Registry (EPREL) provides a reference implementation of the DPP data access API that all DPP systems must be compatible with.
Machine-Readable vs Human-Readable DPP Data
The ESPR regulation distinguishes between data that must be machine-readable (accessible to automated systems without human interpretation) and data that must be human-readable (accessible to consumers and compliance officers without specialised software). Article 9 of ESPR specifies that the Digital Product Passport must be accessible via a data carrier that can be read by both machines and humans. In practice, this means the QR code or NFC tag on the product must resolve to a URL that serves both a human-readable web page (HTML) and a machine-readable data file (JSON-LD, XML, or CSV) at the same URL, using HTTP content negotiation. A market surveillance authority's automated compliance checking system sends an HTTP request with Accept: application/ld+json and receives the machine-readable DPP data. A consumer scans the same QR code and their browser sends Accept: text/html and receives the human-readable product page.
ESPR Data Exchange Formats: JSON-LD, XML, and CSV
The EU Commission's implementing acts under ESPR will specify the exact data exchange formats for each product category's DPP. Based on the Commission's preparatory work and the EU Battery Regulation's DPP specifications (which serve as the template for ESPR), the primary format will be JSON-LD using the W3C Verifiable Credentials Data Model. XML is likely to be supported as an alternative for manufacturers using existing EDI (Electronic Data Interchange) infrastructure. CSV will be supported for bulk data submission to the EU product database. Manufacturers should implement JSON-LD as their primary format and ensure their DPP platform can export data in all three formats to maximise interoperability with supply chain partners, retailers, and market surveillance systems.
API Requirements for Machine-Readable DPP Access
The EU product database established under Article 12 of ESPR will provide a REST API for programmatic access to DPP data. The API will follow the OpenAPI 3.0 specification and will support GET requests for individual product DPPs (by GTIN or product identifier), bulk export of DPP data for a manufacturer's entire product portfolio, and webhook notifications for DPP updates. Third-party DPP platforms that integrate with the EU product database must implement the same API specification to ensure interoperability. Manufacturers that build their own DPP systems must ensure their API is compatible with the EU product database API specification, as market surveillance authorities will use the EU product database as their primary access point for DPP data.
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Register Your Digital Product Passport →Machine-Readable Format Requirements for ESPR DPPs
ESPR requires that DPP data be provided in a machine-readable format that can be processed by automated systems without human intervention. This requirement is fundamental to the DPP concept — the DPP is not just a document for human readers, it is a data object that can be ingested by supply chain management systems, market surveillance tools, AI-powered compliance checkers, and end-of-life processing systems. The machine-readable format requirement ensures that DPP data can be used at scale across the EU's complex supply chains.
The machine-readable format requirements for ESPR DPPs are expected to include: the use of a standardised data schema (such as the ESPR DPP JSON-LD schema); the use of standardised vocabulary terms from recognised ontologies (such as Schema.org, GS1, and the W3C Verifiable Credentials Data Model); the use of standardised identifiers for products, manufacturers, and materials (such as GS1 GTINs, LEI codes for legal entities, and CAS numbers for chemical substances); and the use of standardised units of measurement (SI units for physical quantities, ISO 4217 codes for currencies, and ISO 3166 codes for countries).
The machine-readable format requirements also apply to the data carrier (the QR code or NFC chip that provides access to the DPP). The data carrier must encode the DPP URI in a standardised format (GS1 Digital Link for QR codes) and must meet the technical requirements for readability (minimum size, minimum contrast ratio, minimum error correction level). A QR code that cannot be read by a standard smartphone camera is not compliant with the machine-readable format requirements, regardless of the quality of the DPP data it links to.
Frequently Asked Questions
Machine-readable means that the DPP data can be processed by automated systems without human intervention. This requires the data to be in a standardised format (such as JSON-LD), to use standardised vocabulary terms, and to be accessible via a standardised API. A PDF document is not machine-readable in this sense, even if it contains the required data.
No. ESPR distinguishes between public DPP data (accessible to anyone) and restricted DPP data (accessible only to authorised parties such as market surveillance authorities). The machine-readable format requirements apply to both public and restricted data, but the access control requirements differ. Trade secrets and sensitive business information may be restricted from public access.
Human-readable DPP data is formatted for easy reading by humans (such as a product information sheet or a webpage). Machine-readable DPP data is formatted for processing by automated systems (such as JSON-LD or XML). ESPR requires both — the DPP must be accessible in machine-readable format for automated processing and in human-readable format for consumers and market surveillance authorities.
Small manufacturers may find the machine-readable format requirements challenging to implement without technical support. The Commission is expected to provide guidance and tools to help SMEs comply with the machine-readable format requirements. DPP registry providers (such as the National DPP Registry at digitalproductpassports.co.za) can handle the technical complexity of machine-readable format compliance on behalf of manufacturers.
A DPP that is not in machine-readable format is non-compliant with ESPR requirements. Market surveillance authorities can require manufacturers to correct non-compliant DPPs and may impose penalties for persistent non-compliance. Customs authorities may refuse entry to products with non-compliant DPPs at EU borders.