A note from Carrick Graham
A key lesson for Kiwi exporters is that the information a buyer needs usually exists. Finding the current version is often the difficult part.
A certificate sits in someone's inbox. Product specifications are held in a spreadsheet. The manufacturer has the latest test result. A distributor has an older version of the packaging information. Then a buyer asks for everything by Friday.
New Zealand exporters are good at solving that problem when it appears. But overseas markets are moving towards a system where current product information will need to be available digitally, in a structured form, and connected to the product itself.
Digital product passports are part of that change.
This is not a reason to panic, and it does not mean every exporter faces the same deadline. It is a reason to start organising product data before a customer or regulator sets the timetable.
For New Zealand, there is something larger at stake. Our export reputation has been built on trust, provenance and quality. The next challenge is making those qualities easier to verify at product level.
The wake-up call
The European Union has established the Digital Product Passport through its Ecodesign for Sustainable Products Regulation. The framework has been in force since July 2024, the EU's shared passport registry went live in July 2026, and the first binding passport deadline arrives for certain batteries in February 2027 (European Commission, European Commission DPP Registry).
Other product groups will follow through separate rules over several years.
This does not mean every New Zealand exporter needs a digital product passport tomorrow. Food and feed are excluded from the main Ecodesign for Sustainable Products Regulation, and detailed requirements for most other products are still being developed.
But the direction is clear. Products entering major markets are moving towards a persistent digital identity that can carry current, structured and verifiable information through the supply chain.
The immediate question for an exporter is not, "Do we need a digital product passport today?"
It is, "If a buyer or regulator asked us to produce a current digital record for each product, how quickly could we do it?"
If the answer depends on several people searching old emails and spreadsheets, the business is not ready.
What a digital product passport actually is
The simplest way to think about a digital product passport is as a current digital record for a physical product.
The EU defines it as a product-specific set of data reached electronically through a data carrier. Depending on the product category, that data may cover materials, environmental performance, repairability, recycled content, technical documentation, traceability or other compliance requirements (EUR-Lex).
Each passport will be linked to a persistent product identifier. The data must be structured, machine-readable, interoperable and kept accurate, complete and up to date. Access rights will vary by product rule and user. A customer may see one set of information, while a regulator, customs authority, repairer or recycler may have access to another (EUR-Lex).
A QR code alone is not a digital product passport. The passport is the product-specific data set. The QR code or other data carrier is how people and systems reach it. The applicable product rules determine what information must be included, who can see it and how it must be maintained.
The EU registry stores identifiers and registration information, rather than every piece of detailed product data. The underlying information remains with the relevant economic operator or its service provider. New Zealand exporters will therefore need to agree data and updating responsibilities with their EU importer or other operator (European Commission, EUR-Lex).
What is confirmed and what is still developing
| Confirmed | Still developing |
|---|---|
| The EU's Digital Product Passport framework is in force. | The detailed data fields for most product categories. |
| Certain electric vehicle, light means of transport (LMT) and industrial batteries above 2 kWh require battery passports from 18 February 2027 (EUR-Lex). | The final compliance dates for most other product categories. |
| Detailed rules will be introduced product by product. | How some sector standards and technical systems will operate in practice. |
| Businesses will generally receive at least 18 months after a delegated act is adopted before it applies (EUR-Lex). | Which current business systems will need replacing, connecting or adapting. |
The European Commission's indicative programme covers iron and steel, energy-related products, textiles and apparel, tyres, aluminium, furniture, mattresses and ICT products between 2026 and 2029. These are rulemaking periods, not blanket compliance dates (European Commission).
GS1's 2027 ambition is related, but separate. It aims for retail point-of-sale systems to be capable of reading product identifiers from both existing linear and 2D barcodes by the end of 2027. It is an industry capability target, not a law requiring every exporter to replace every barcode in 2027. Linear barcodes will continue to coexist during the transition (GS1).
The sensible response is not to guess at rules that have not been written. It is to prepare the product information that any workable system will need.
Why this matters to New Zealand
New Zealand exported $84 billion in goods in the year ended June 2026. The EU is already our fourth-largest goods export market (Stats NZ).
The New Zealand-EU Free Trade Agreement has improved access to a market of almost 450 million people. In the year to June 2025, New Zealand goods exports to the EU increased 28% to $7.88 billion, while 91% of our existing goods trade entered the EU duty-free (MFAT).
Lower tariffs help. They do not remove the need to meet product rules.
MFAT has warned that the EU's ecodesign and digital product passport regime will reshape market access. It recommends that affected exporters begin auditing their products, processes and data systems, while acknowledging that a complete compliance audit may not be possible until each category's detailed rules are finalised (MFAT).
The existing compliance burden is already significant. Research commissioned by MFAT and published in 2022 estimated that at least 83% of New Zealand exports were covered by non-tariff measures, with annual compliance costs above $12 billion. Each product faced an average of nine such measures across export markets. These figures are not an estimate of DPP costs. They show the scale of the cross-market burden exporters already manage (MFAT and Sense Partners).
Digital product passports will not remove every requirement. They can provide a better structure for maintaining and sharing the information behind them.
Three exporters, three versions of the same problem
A clothing brand selling into Europe
A New Zealand clothing company may eventually need to provide product information covering materials, durability, repairability, environmental performance or other requirements set under an EU textile rule.
The final data fields and compliance date are not yet settled. The preparation work is still obvious. The company needs reliable product identifiers, current fibre and material information, supplier evidence and someone responsible for maintaining it.
If those records are scattered across the brand, manufacturer and freight partner, the future deadline will expose an existing data problem.
A food exporter carrying the FernMark
Food and feed are excluded from the main EU ecodesign framework. A Kiwi food producer should not be told that an ESPR passport is about to become mandatory for its products.
The business may still face changing packaging, labelling, traceability and environmental-claims requirements. Initial obligations under the EU Packaging and Packaging Waste Regulation apply from 12 August 2026, packaging QR requirements are scheduled from August 2028, and evidence requirements for covered environmental and social claims apply from 27 September 2026 (NZTE packaging guidance, NZTE green-claims guidance).
For a FernMark licensee, there is an additional opportunity. The FernMark Licence Programme is the Government's official country-of-origin accreditation. It enables eligible exporters to use a national symbol that signals an authentic connection to Aotearoa New Zealand (FernMark Licence Programme).
That signal is valuable. A digital product identity can extend it by connecting a specific product to current information about provenance, ingredients, manufacturing, certification or other evidence the brand chooses or is required to share.
The FernMark does not replace a digital product passport, and holding a FernMark licence does not create a DPP obligation. The opportunity is to build on an existing mark of trust with product-level information that can be kept current.
A manufacturer supplying another company's product
A New Zealand component manufacturer may never sell directly to a European consumer. Its material or technical information may still be needed by an overseas customer creating a passport for the finished product.
The request may arrive through the supply chain rather than from a regulator. The manufacturer will need to know what it can provide, what is confidential, who can approve it and how changes will be communicated.
This is why DPP readiness is not only an issue for consumer brands. It can become a condition of remaining a trusted supplier.
From FernMark trust to product-level proof
The FernMark Programme describes the mark as government-backed country-of-origin accreditation and a signal of trust, safety and provenance. Eligible businesses must meet criteria including compliance with New Zealand laws, an established export record and a sufficient New Zealand connection. Each licensed product is assessed against requirements for being made, grown or designed in New Zealand (FernMark eligibility, FernMark Programme).
That makes FernMark licensees a natural audience for digital product identity.
They are already investing in a trusted New Zealand origin story. They also have products, markets and evidence that need to be managed over time. A persistent product record can help connect the national mark to the current information behind an individual SKU.
This should not become another unsupported marketing claim. A digital product record is only as credible as its source information, approvals and maintenance. The aim is not to put every confidential document in public. It is to give the right audience access to the right information, backed by an accountable process.
New Zealand Story has previously described how FernMark licensees can use an adjacent QR code to help customers verify provenance and reach further brand information. Digital product passports take the broader concept further by introducing structured data, differentiated access and category-specific regulatory requirements (New Zealand Story).
For FernMark brands, the strategic question is straightforward: can the trust signalled on the package be supported by current product-level evidence when a buyer, distributor or customer wants to look further?
The NZ Inc opportunity
New Zealand has spent decades building a reputation around provenance, quality, food safety and responsible production.
The next competitive advantage will not come from repeating those words more often. It will come from making the evidence easier to verify.
Digital product identity gives exporters a way to connect the physical product with its compliance information, provenance, certifications and approved brand material. It gives buyers a clearer view of what they are purchasing and gives exporters one current source to maintain.
MFAT has described the passport as a potential "one stop shop" for compliance information and an opportunity to increase transparency and trust in a market that values provenance and sustainability credentials (MFAT).
There is also a wider system opportunity.
If exporters, certifiers, industry bodies and public agencies use common identifiers and interoperable data standards, the same verified information can be reused rather than recreated for every market request. That will not eliminate the need to meet different rules. It can reduce the repeated work involved in finding and checking the same underlying evidence.
For NZ Inc, the advantage will not come from being first to print more QR codes. It will come from making trusted New Zealand product information easier to verify and easier to use.
The exporter readiness test
Answering "no" or "not sure" does not mean a business is failing. It identifies where the preparation should start.
- Does every export SKU have a unique, persistent and correctly assigned product identifier?
- Is there one current source for specifications, declarations, certificates and supporting evidence?
- Does each important data field have a named owner who can approve changes?
- Are certificate expiries, supplier changes and other update triggers recorded?
- Can the business distinguish information for buyers, regulators and customers from confidential data?
- Can information be updated without changing the product identifier or reprinting the packaging?
- Are data and updating responsibilities agreed with overseas importers, distributors and suppliers?
- Can the business export or move its data if it changes technology providers?
- For FernMark products, is the licensed product's New Zealand connection supported by current product-level information?
Six practical steps to take now
1. Map the markets and rules
Check where each product is sold and which rules may apply. Include products entering Europe through an importer, distributor, marketplace or as a component of someone else's finished product.
2. Give each product a reliable identity
Check that product identifiers are unique, persistent and correctly assigned. GS1 New Zealand places this first in its preparation guidance (GS1 New Zealand).
3. Find the current information
List where specifications, test results, declarations, certificates, ingredient or material data, supplier evidence and market-specific documents sit today. Do not begin by buying software. Begin by finding the information and the gaps.
4. Assign ownership
Give someone responsibility for creating, checking, approving and updating each important field. Record expiry dates and change triggers. A passport that is not maintained creates a new compliance problem rather than solving one.
5. Test with several SKUs
Choose products that represent different markets or data challenges. For FernMark licensees, include one or more licensed products and test how provenance information and the licence sit alongside wider product and compliance data.
6. Choose open standards and keep control
Any platform should support interoperable, machine-readable data, differentiated access, reliable backups, controlled updating and data portability. The EU framework requires open standards and includes protections against vendor lock-in (EUR-Lex).
What a practical digital product system should provide
Technology should make the information easier to manage, not create another isolated database. A practical system should provide:
- A persistent digital identity for each product
- A reliable link between the product identifier and its current information
- Structured fields that can adapt as market requirements develop
- Separate views and permissions for regulators, buyers, partners and customers
- Clear ownership, approval and updating controls
- Expiry and change management for certificates and supporting records
- Interoperability, data portability and reliable backup
- Space for provenance and brand information alongside compliance data
No platform can make an exporter compliant simply by issuing a QR code. Compliance depends on the product, market, evidence and processes behind it.
OwlQR is being developed in New Zealand around this practical need: one digital identity for each product, with compliance, sourcing, manufacturing and approved customer information managed in one place and reached through a persistent QR code.
The conclusion
Digital product passports will arrive at different times for different products. Buyer and supply-chain expectations may move sooner.
Kiwi exporters do not need to predict every future data field before beginning. They can identify their products, organise the information they already hold, close the obvious gaps and test how it will be maintained. That preparation is especially relevant to FernMark licensees. They already carry an official signal of New Zealand origin. The opportunity is to support that signal with current product-level information that buyers and customers can verify.
The businesses that start organising their product data now will not only be better prepared for regulation. They will be easier for overseas buyers to trust and easier to do business with.
New Zealand has a strong export story. The next step is making the proof behind it as accessible as the story itself.
About the author
Carrick Graham is a co-founder and director of OwlQR, a New Zealand-built digital product identity platform. This briefing reflects his work with exporters preparing product and compliance information for changing market requirements.