@tracepass/dpp-schemas 1.10.5 → 1.10.7

package/templates/paints-coatings.json

@@ -96,10 +96,7 @@
       "defaultValue": null,
       "enumOptions": [],
       "validation": {
-        "required": false,
-        "anticipated": true,
-        "anticipatedUnder": "32024R1781",
-        "anticipatedNote": "ESPR Art. 9(1) requires a unique product identifier, but only once a product-group delegated act under Art. 4 applies to chemicals; none adopted."
+        "required": false
       },
       "category": "product_id",
       "categoryLabel": {
@@ -135,7 +132,7 @@
         "instrument": "32024R1781",
         "provision": "Article 9(1)",
         "kind": "legislation",
-        "description": "ESPR 32024R1781 mandates no product data of its own. Art. 7(1) makes information requirements those 'laid down in the delegated acts adopted pursuant to Article 4'; Art. 9(2) says those acts 'shall … specify' what a passport carries; and Art. 27 binds manufacturers only 'when placing products COVERED BY a delegated act adopted pursuant to Article 4' on the market. All three defer to an Art. 4 act, and none is adopted for this category — so this field is anticipated, not required. Verified against the EUR-Lex text."
+        "description": "ESPR 32024R1781 mandates no product data of its own. Art. 7(1) makes information requirements those 'laid down in the delegated acts adopted pursuant to Article 4'; Art. 9(2) says those acts 'shall … specify' what a passport carries; and Art. 27 binds manufacturers only 'when placing products COVERED BY a delegated act adopted pursuant to Article 4' on the market. All three defer to an Art. 4 act, and none is adopted for this category — and none is scheduled: the ESPR working plan COM(2025) 187 leaves paints out — so this field is optional. Verified against the EUR-Lex text."
       },
       "aiHints": {
         "alternateNames": [
@@ -207,10 +204,7 @@
       "defaultValue": null,
       "enumOptions": [],
       "validation": {
-        "required": false,
-        "anticipated": true,
-        "anticipatedUnder": "32024R1781",
-        "anticipatedNote": "A DPP identifier is anticipated under an ESPR Art. 9 delegated act; GTIN is a GS1 implementation choice, not itself a legal requirement."
+        "required": false
       },
       "category": "product_id",
       "categoryLabel": {
@@ -246,7 +240,7 @@
         "instrument": "32024R1781",
         "provision": "Article 9, GS1",
         "kind": "legislation",
-        "description": "ESPR 32024R1781 mandates no product data of its own. Art. 7(1) makes information requirements those 'laid down in the delegated acts adopted pursuant to Article 4'; Art. 9(2) says those acts 'shall … specify' what a passport carries; and Art. 27 binds manufacturers only 'when placing products COVERED BY a delegated act adopted pursuant to Article 4' on the market. All three defer to an Art. 4 act, and none is adopted for this category — so this field is anticipated, not required. Verified against the EUR-Lex text."
+        "description": "ESPR 32024R1781 mandates no product data of its own. Art. 7(1) makes information requirements those 'laid down in the delegated acts adopted pursuant to Article 4'; Art. 9(2) says those acts 'shall … specify' what a passport carries; and Art. 27 binds manufacturers only 'when placing products COVERED BY a delegated act adopted pursuant to Article 4' on the market. All three defer to an Art. 4 act, and none is adopted for this category — and none is scheduled: the ESPR working plan COM(2025) 187 leaves paints out — so this field is optional. Verified against the EUR-Lex text."
       },
       "aiHints": {
         "alternateNames": [
@@ -462,7 +456,7 @@
         "instrument": "32024R1781",
         "provision": "Article 9",
         "kind": "legislation",
-        "description": "ESPR 32024R1781 mandates no product data of its own. Art. 7(1) makes information requirements those 'laid down in the delegated acts adopted pursuant to Article 4'; Art. 9(2) says those acts 'shall … specify' what a passport carries; and Art. 27 binds manufacturers only 'when placing products COVERED BY a delegated act adopted pursuant to Article 4' on the market. All three defer to an Art. 4 act, and none is adopted for this category — so this field is anticipated, not required. Verified against the EUR-Lex text."
+        "description": "ESPR 32024R1781 mandates no product data of its own. Art. 7(1) makes information requirements those 'laid down in the delegated acts adopted pursuant to Article 4'; Art. 9(2) says those acts 'shall … specify' what a passport carries; and Art. 27 binds manufacturers only 'when placing products COVERED BY a delegated act adopted pursuant to Article 4' on the market. All three defer to an Art. 4 act, and none is adopted for this category — and none is scheduled: the ESPR working plan COM(2025) 187 leaves paints out — so this field is optional. Verified against the EUR-Lex text."
       },
       "aiHints": {
         "alternateNames": [
@@ -677,7 +671,7 @@
         "instrument": "32024R1781",
         "provision": "Article 9",
         "kind": "legislation",
-        "description": "ESPR 32024R1781 mandates no product data of its own. Art. 7(1) makes information requirements those 'laid down in the delegated acts adopted pursuant to Article 4'; Art. 9(2) says those acts 'shall … specify' what a passport carries; and Art. 27 binds manufacturers only 'when placing products COVERED BY a delegated act adopted pursuant to Article 4' on the market. All three defer to an Art. 4 act, and none is adopted for this category — so this field is anticipated, not required. Verified against the EUR-Lex text."
+        "description": "ESPR 32024R1781 mandates no product data of its own. Art. 7(1) makes information requirements those 'laid down in the delegated acts adopted pursuant to Article 4'; Art. 9(2) says those acts 'shall … specify' what a passport carries; and Art. 27 binds manufacturers only 'when placing products COVERED BY a delegated act adopted pursuant to Article 4' on the market. All three defer to an Art. 4 act, and none is adopted for this category — and none is scheduled: the ESPR working plan COM(2025) 187 leaves paints out — so this field is optional. Verified against the EUR-Lex text."
       },
       "aiHints": {
         "alternateNames": [
@@ -785,7 +779,7 @@
         "instrument": "32024R1781",
         "provision": "Article 9",
         "kind": "legislation",
-        "description": "ESPR 32024R1781 mandates no product data of its own. Art. 7(1) makes information requirements those 'laid down in the delegated acts adopted pursuant to Article 4'; Art. 9(2) says those acts 'shall … specify' what a passport carries; and Art. 27 binds manufacturers only 'when placing products COVERED BY a delegated act adopted pursuant to Article 4' on the market. All three defer to an Art. 4 act, and none is adopted for this category — so this field is anticipated, not required. Verified against the EUR-Lex text."
+        "description": "ESPR 32024R1781 mandates no product data of its own. Art. 7(1) makes information requirements those 'laid down in the delegated acts adopted pursuant to Article 4'; Art. 9(2) says those acts 'shall … specify' what a passport carries; and Art. 27 binds manufacturers only 'when placing products COVERED BY a delegated act adopted pursuant to Article 4' on the market. All three defer to an Art. 4 act, and none is adopted for this category — and none is scheduled: the ESPR working plan COM(2025) 187 leaves paints out — so this field is optional. Verified against the EUR-Lex text."
       },
       "aiHints": {
         "alternateNames": [
@@ -1255,10 +1249,7 @@
         }
       ],
       "validation": {
-        "required": false,
-        "anticipated": true,
-        "anticipatedUnder": "32024R1781",
-        "anticipatedNote": "A category field would be defined by the future ESPR chemicals delegated act; not mandated today."
+        "required": false
       },
       "category": "product_id",
       "categoryLabel": {
@@ -1294,7 +1285,7 @@
         "instrument": "32024R1781",
         "provision": "Article 9",
         "kind": "legislation",
-        "description": "ESPR 32024R1781 mandates no product data of its own. Art. 7(1) makes information requirements those 'laid down in the delegated acts adopted pursuant to Article 4'; Art. 9(2) says those acts 'shall … specify' what a passport carries; and Art. 27 binds manufacturers only 'when placing products COVERED BY a delegated act adopted pursuant to Article 4' on the market. All three defer to an Art. 4 act, and none is adopted for this category — so this field is anticipated, not required. Verified against the EUR-Lex text."
+        "description": "ESPR 32024R1781 mandates no product data of its own. Art. 7(1) makes information requirements those 'laid down in the delegated acts adopted pursuant to Article 4'; Art. 9(2) says those acts 'shall … specify' what a passport carries; and Art. 27 binds manufacturers only 'when placing products COVERED BY a delegated act adopted pursuant to Article 4' on the market. All three defer to an Art. 4 act, and none is adopted for this category — and none is scheduled: the ESPR working plan COM(2025) 187 leaves paints out — so this field is optional. Verified against the EUR-Lex text."
       },
       "aiHints": {
         "alternateNames": [
@@ -1401,7 +1392,7 @@
         "instrument": "32024R1781",
         "provision": "Article 9",
         "kind": "legislation",
-        "description": "ESPR 32024R1781 mandates no product data of its own. Art. 7(1) makes information requirements those 'laid down in the delegated acts adopted pursuant to Article 4'; Art. 9(2) says those acts 'shall … specify' what a passport carries; and Art. 27 binds manufacturers only 'when placing products COVERED BY a delegated act adopted pursuant to Article 4' on the market. All three defer to an Art. 4 act, and none is adopted for this category — so this field is anticipated, not required. Verified against the EUR-Lex text."
+        "description": "ESPR 32024R1781 mandates no product data of its own. Art. 7(1) makes information requirements those 'laid down in the delegated acts adopted pursuant to Article 4'; Art. 9(2) says those acts 'shall … specify' what a passport carries; and Art. 27 binds manufacturers only 'when placing products COVERED BY a delegated act adopted pursuant to Article 4' on the market. All three defer to an Art. 4 act, and none is adopted for this category — and none is scheduled: the ESPR working plan COM(2025) 187 leaves paints out — so this field is optional. Verified against the EUR-Lex text."
       },
       "aiHints": {
         "alternateNames": [
@@ -1505,11 +1496,11 @@
       "sortOrder": 11,
       "defaultAccessLevel": "public",
       "regulationRef": {
-        "article": "CLP Art. 17(1)(a); GPSR Art. 9(6)",
+        "article": "CLP Art. 17(1)(a); REACH Annex II 1.3",
         "instrument": "32008R1272",
         "provision": "Art. 17(1)(a)",
         "kind": "legislation",
-        "description": "CLP Art. 17(1)(a) names the supplier on the label of classified mixtures, and GPSR Art. 9(6) the manufacturer on consumer products. Marking duties, not passport data; paints carry no passport duty."
+        "description": "CLP Art. 17(1)(a) names the supplier on the label of mixtures classified as hazardous, and REACH Annex II section 1.3 on the safety data sheet. GPSR Art. 9(6) does not apply: CLP and the Decopaint Directive are Union harmonisation legislation (Reg. (EU) 2019/1020 Annex I), so GPSR Art. 2(1)(b) disapplies Chapter III Section 1. Marking duties, not passport data; paints carry no passport duty."
       },
       "aiHints": {
         "alternateNames": [
@@ -1613,11 +1604,11 @@
       "sortOrder": 12,
       "defaultAccessLevel": "public",
       "regulationRef": {
-        "article": "CLP Art. 17(1)(a); GPSR Art. 9(6)",
+        "article": "CLP Art. 17(1)(a); REACH Annex II 1.3",
         "instrument": "32008R1272",
         "provision": "Art. 17(1)(a)",
         "kind": "legislation",
-        "description": "CLP Art. 17(1)(a) names the supplier on the label of classified mixtures, and GPSR Art. 9(6) the manufacturer on consumer products. Marking duties, not passport data; paints carry no passport duty."
+        "description": "CLP Art. 17(1)(a) names the supplier on the label of mixtures classified as hazardous, and REACH Annex II section 1.3 on the safety data sheet. GPSR Art. 9(6) does not apply: CLP and the Decopaint Directive are Union harmonisation legislation (Reg. (EU) 2019/1020 Annex I), so GPSR Art. 2(1)(b) disapplies Chapter III Section 1. Marking duties, not passport data; paints carry no passport duty."
       },
       "aiHints": {
         "alternateNames": [
@@ -1903,10 +1894,7 @@
       "defaultValue": null,
       "enumOptions": [],
       "validation": {
-        "required": false,
-        "anticipated": true,
-        "anticipatedUnder": "32024R1781",
-        "anticipatedNote": "ESPR Art. 9/Annex III anticipates operator identifiers in a DPP, but only under a delegated act; not in force."
+        "required": false
       },
       "category": "economic_operator",
       "categoryLabel": {
@@ -1942,7 +1930,7 @@
         "instrument": "32024R1781",
         "provision": "Article 9",
         "kind": "legislation",
-        "description": "ESPR 32024R1781 mandates no product data of its own. Art. 7(1) makes information requirements those 'laid down in the delegated acts adopted pursuant to Article 4'; Art. 9(2) says those acts 'shall … specify' what a passport carries; and Art. 27 binds manufacturers only 'when placing products COVERED BY a delegated act adopted pursuant to Article 4' on the market. All three defer to an Art. 4 act, and none is adopted for this category — so this field is anticipated, not required. Verified against the EUR-Lex text."
+        "description": "ESPR 32024R1781 mandates no product data of its own. Art. 7(1) makes information requirements those 'laid down in the delegated acts adopted pursuant to Article 4'; Art. 9(2) says those acts 'shall … specify' what a passport carries; and Art. 27 binds manufacturers only 'when placing products COVERED BY a delegated act adopted pursuant to Article 4' on the market. All three defer to an Art. 4 act, and none is adopted for this category — and none is scheduled: the ESPR working plan COM(2025) 187 leaves paints out — so this field is optional. Verified against the EUR-Lex text."
       },
       "aiHints": {
         "alternateNames": [
@@ -2047,11 +2035,11 @@
       "sortOrder": 16,
       "defaultAccessLevel": "public",
       "regulationRef": {
-        "article": "ESPR Art. 9",
-        "instrument": "32024R1781",
-        "provision": "Article 9",
+        "article": "CLP Art. 17(1)(a); REACH Annex II 1.3",
+        "instrument": "32008R1272",
+        "provision": "Art. 17(1)(a)",
         "kind": "legislation",
-        "description": "ESPR 32024R1781 mandates no product data of its own. Art. 7(1) makes information requirements those 'laid down in the delegated acts adopted pursuant to Article 4'; Art. 9(2) says those acts 'shall … specify' what a passport carries; and Art. 27 binds manufacturers only 'when placing products COVERED BY a delegated act adopted pursuant to Article 4' on the market. All three defer to an Art. 4 act, and none is adopted for this category — so this field is anticipated, not required. Verified against the EUR-Lex text."
+        "description": "Conditional on the importer being the supplier placing the mixture on the market: CLP requires the supplier's name, address and telephone number on the label of a mixture classified as hazardous, and REACH Annex II section 1.3 on its safety data sheet; an unclassified paint carries no such duty. GPSR Art. 11(3) does not apply, because CLP and the Decopaint Directive are Union harmonisation legislation (Reg. (EU) 2019/1020 Annex I) and GPSR Art. 2(1)(b) disapplies Chapter III Section 1. ESPR is no basis: the 2025–2030 working plan (COM(2025) 187) leaves paints out."
       },
       "aiHints": {
         "alternateNames": [
@@ -2154,11 +2142,11 @@
       "sortOrder": 17,
       "defaultAccessLevel": "public",
       "regulationRef": {
-        "article": "ESPR Art. 9",
-        "instrument": "32024R1781",
-        "provision": "Article 9",
+        "article": "CLP Art. 17(1)(a); REACH Annex II 1.3",
+        "instrument": "32008R1272",
+        "provision": "Art. 17(1)(a)",
         "kind": "legislation",
-        "description": "ESPR 32024R1781 mandates no product data of its own. Art. 7(1) makes information requirements those 'laid down in the delegated acts adopted pursuant to Article 4'; Art. 9(2) says those acts 'shall … specify' what a passport carries; and Art. 27 binds manufacturers only 'when placing products COVERED BY a delegated act adopted pursuant to Article 4' on the market. All three defer to an Art. 4 act, and none is adopted for this category — so this field is anticipated, not required. Verified against the EUR-Lex text."
+        "description": "Conditional on the importer being the supplier placing the mixture on the market: CLP requires the supplier's name, address and telephone number on the label of a mixture classified as hazardous, and REACH Annex II section 1.3 on its safety data sheet; an unclassified paint carries no such duty. GPSR Art. 11(3) does not apply, because CLP and the Decopaint Directive are Union harmonisation legislation (Reg. (EU) 2019/1020 Annex I) and GPSR Art. 2(1)(b) disapplies Chapter III Section 1. ESPR is no basis: the 2025–2030 working plan (COM(2025) 187) leaves paints out."
       },
       "aiHints": {
         "alternateNames": [
@@ -2264,7 +2252,7 @@
         "instrument": "32024R1781",
         "provision": "Article 9",
         "kind": "legislation",
-        "description": "ESPR 32024R1781 mandates no product data of its own. Art. 7(1) makes information requirements those 'laid down in the delegated acts adopted pursuant to Article 4'; Art. 9(2) says those acts 'shall … specify' what a passport carries; and Art. 27 binds manufacturers only 'when placing products COVERED BY a delegated act adopted pursuant to Article 4' on the market. All three defer to an Art. 4 act, and none is adopted for this category — so this field is anticipated, not required. Verified against the EUR-Lex text."
+        "description": "ESPR 32024R1781 mandates no product data of its own. Art. 7(1) makes information requirements those 'laid down in the delegated acts adopted pursuant to Article 4'; Art. 9(2) says those acts 'shall … specify' what a passport carries; and Art. 27 binds manufacturers only 'when placing products COVERED BY a delegated act adopted pursuant to Article 4' on the market. All three defer to an Art. 4 act, and none is adopted for this category — and none is scheduled: the ESPR working plan COM(2025) 187 leaves paints out — so this field is optional. Verified against the EUR-Lex text."
       },
       "aiHints": {
         "alternateNames": [
@@ -2335,10 +2323,7 @@
       "defaultValue": "TracePass",
       "enumOptions": [],
       "validation": {
-        "required": false,
-        "anticipated": true,
-        "anticipatedUnder": "32024R1781",
-        "anticipatedNote": "The passport-service-provider role exists in the ESPR DPP architecture (Art. 10 area) but binds no chemicals product until a delegated act applies."
+        "required": false
       },
       "category": "economic_operator",
       "categoryLabel": {
@@ -2374,7 +2359,7 @@
         "instrument": "32024R1781",
         "provision": "Article 10",
         "kind": "legislation",
-        "description": "ESPR Art. 10 governs the passport's TECHNICAL design — data carrier, unique identifiers, access rights, availability — not which product data must be published. The substantive obligation still arrives via an Art. 4 delegated act, and none is adopted for this category. Anticipated; voluntary today. Verified against the EUR-Lex text."
+        "description": "ESPR Art. 10 governs the passport's TECHNICAL design — data carrier, unique identifiers, access rights, availability — not which product data must be published. The substantive obligation still arrives via an Art. 4 delegated act, and none is adopted for this category. None is scheduled either: the ESPR working plan COM(2025) 187 leaves paints out. Optional. Verified against the EUR-Lex text."
       },
       "aiHints": {
         "alternateNames": [
@@ -2481,7 +2466,7 @@
         "instrument": "32024R1781",
         "provision": "Article 9",
         "kind": "legislation",
-        "description": "ESPR 32024R1781 mandates no product data of its own. Art. 7(1) makes information requirements those 'laid down in the delegated acts adopted pursuant to Article 4'; Art. 9(2) says those acts 'shall … specify' what a passport carries; and Art. 27 binds manufacturers only 'when placing products COVERED BY a delegated act adopted pursuant to Article 4' on the market. All three defer to an Art. 4 act, and none is adopted for this category — so this field is anticipated, not required. Verified against the EUR-Lex text."
+        "description": "ESPR 32024R1781 mandates no product data of its own. Art. 7(1) makes information requirements those 'laid down in the delegated acts adopted pursuant to Article 4'; Art. 9(2) says those acts 'shall … specify' what a passport carries; and Art. 27 binds manufacturers only 'when placing products COVERED BY a delegated act adopted pursuant to Article 4' on the market. All three defer to an Art. 4 act, and none is adopted for this category — and none is scheduled: the ESPR working plan COM(2025) 187 leaves paints out — so this field is optional. Verified against the EUR-Lex text."
       },
       "aiHints": {
         "alternateNames": [
@@ -2553,10 +2538,7 @@
       "defaultValue": null,
       "enumOptions": [],
       "validation": {
-        "required": false,
-        "anticipated": true,
-        "anticipatedUnder": "32024R1781",
-        "anticipatedNote": "Anticipated DPP content under ESPR Art. 9(2)/Annex III"
+        "required": false
       },
       "category": "economic_operator",
       "categoryLabel": {
@@ -2592,7 +2574,7 @@
         "instrument": "32024R1781",
         "provision": "Article 9",
         "kind": "legislation",
-        "description": "ESPR 32024R1781 mandates no product data of its own. Art. 7(1) makes information requirements those 'laid down in the delegated acts adopted pursuant to Article 4'; Art. 9(2) says those acts 'shall … specify' what a passport carries; and Art. 27 binds manufacturers only 'when placing products COVERED BY a delegated act adopted pursuant to Article 4' on the market. All three defer to an Art. 4 act, and none is adopted for this category — so this field is anticipated, not required. Verified against the EUR-Lex text."
+        "description": "ESPR 32024R1781 mandates no product data of its own. Art. 7(1) makes information requirements those 'laid down in the delegated acts adopted pursuant to Article 4'; Art. 9(2) says those acts 'shall … specify' what a passport carries; and Art. 27 binds manufacturers only 'when placing products COVERED BY a delegated act adopted pursuant to Article 4' on the market. All three defer to an Art. 4 act, and none is adopted for this category — and none is scheduled: the ESPR working plan COM(2025) 187 leaves paints out — so this field is optional. Verified against the EUR-Lex text."
       },
       "aiHints": {
         "alternateNames": [
@@ -4636,7 +4618,7 @@
         "instrument": "32024R1781",
         "provision": "Article 7(5)(b)",
         "kind": "legislation",
-        "description": "ESPR 32024R1781 mandates no product data of its own. Art. 7(1) makes information requirements those 'laid down in the delegated acts adopted pursuant to Article 4'; Art. 9(2) says those acts 'shall … specify' what a passport carries; and Art. 27 binds manufacturers only 'when placing products COVERED BY a delegated act adopted pursuant to Article 4' on the market. All three defer to an Art. 4 act, and none is adopted for this category — so this field is anticipated, not required. Verified against the EUR-Lex text."
+        "description": "ESPR 32024R1781 mandates no product data of its own. Art. 7(1) makes information requirements those 'laid down in the delegated acts adopted pursuant to Article 4'; Art. 9(2) says those acts 'shall … specify' what a passport carries; and Art. 27 binds manufacturers only 'when placing products COVERED BY a delegated act adopted pursuant to Article 4' on the market. All three defer to an Art. 4 act, and none is adopted for this category — and none is scheduled: the ESPR working plan COM(2025) 187 leaves paints out — so this field is optional. Verified against the EUR-Lex text."
       },
       "aiHints": {
         "alternateNames": [
@@ -5595,7 +5577,7 @@
         "instrument": "32024R1781",
         "provision": "Article 7(2)(b)",
         "kind": "legislation",
-        "description": "ESPR 32024R1781 mandates no product data of its own. Art. 7(1) makes information requirements those 'laid down in the delegated acts adopted pursuant to Article 4'; Art. 9(2) says those acts 'shall … specify' what a passport carries; and Art. 27 binds manufacturers only 'when placing products COVERED BY a delegated act adopted pursuant to Article 4' on the market. All three defer to an Art. 4 act, and none is adopted for this category — so this field is anticipated, not required. Verified against the EUR-Lex text."
+        "description": "ESPR 32024R1781 mandates no product data of its own. Art. 7(1) makes information requirements those 'laid down in the delegated acts adopted pursuant to Article 4'; Art. 9(2) says those acts 'shall … specify' what a passport carries; and Art. 27 binds manufacturers only 'when placing products COVERED BY a delegated act adopted pursuant to Article 4' on the market. All three defer to an Art. 4 act, and none is adopted for this category — and none is scheduled: the ESPR working plan COM(2025) 187 leaves paints out — so this field is optional. Verified against the EUR-Lex text."
       },
       "aiHints": {
         "alternateNames": [
@@ -5762,7 +5744,7 @@
         "instrument": "32024R1781",
         "provision": "Article 7(2)(b)",
         "kind": "legislation",
-        "description": "ESPR 32024R1781 mandates no product data of its own. Art. 7(1) makes information requirements those 'laid down in the delegated acts adopted pursuant to Article 4'; Art. 9(2) says those acts 'shall … specify' what a passport carries; and Art. 27 binds manufacturers only 'when placing products COVERED BY a delegated act adopted pursuant to Article 4' on the market. All three defer to an Art. 4 act, and none is adopted for this category — so this field is anticipated, not required. Verified against the EUR-Lex text."
+        "description": "ESPR 32024R1781 mandates no product data of its own. Art. 7(1) makes information requirements those 'laid down in the delegated acts adopted pursuant to Article 4'; Art. 9(2) says those acts 'shall … specify' what a passport carries; and Art. 27 binds manufacturers only 'when placing products COVERED BY a delegated act adopted pursuant to Article 4' on the market. All three defer to an Art. 4 act, and none is adopted for this category — and none is scheduled: the ESPR working plan COM(2025) 187 leaves paints out — so this field is optional. Verified against the EUR-Lex text."
       },
       "aiHints": {
         "alternateNames": [
@@ -5869,7 +5851,7 @@
         "instrument": "32024R1781",
         "provision": "Article 7(2)(b)",
         "kind": "legislation",
-        "description": "ESPR 32024R1781 mandates no product data of its own. Art. 7(1) makes information requirements those 'laid down in the delegated acts adopted pursuant to Article 4'; Art. 9(2) says those acts 'shall … specify' what a passport carries; and Art. 27 binds manufacturers only 'when placing products COVERED BY a delegated act adopted pursuant to Article 4' on the market. All three defer to an Art. 4 act, and none is adopted for this category — so this field is anticipated, not required. Verified against the EUR-Lex text."
+        "description": "ESPR 32024R1781 mandates no product data of its own. Art. 7(1) makes information requirements those 'laid down in the delegated acts adopted pursuant to Article 4'; Art. 9(2) says those acts 'shall … specify' what a passport carries; and Art. 27 binds manufacturers only 'when placing products COVERED BY a delegated act adopted pursuant to Article 4' on the market. All three defer to an Art. 4 act, and none is adopted for this category — and none is scheduled: the ESPR working plan COM(2025) 187 leaves paints out — so this field is optional. Verified against the EUR-Lex text."
       },
       "aiHints": {
         "alternateNames": [
@@ -5941,10 +5923,7 @@
       "defaultValue": null,
       "enumOptions": [],
       "validation": {
-        "required": false,
-        "anticipated": true,
-        "anticipatedUnder": "32024R1781",
-        "anticipatedNote": "Pending a product-group delegated act under ESPR Art. 4; no instrument in force compels this."
+        "required": false
       },
       "category": "environmental",
       "categoryLabel": {
@@ -5978,7 +5957,7 @@
       "regulationRef": {
         "instrument": "32024R1781",
         "kind": "legislation",
-        "description": "ESPR 32024R1781 mandates no product data of its own. Art. 7(1) makes information requirements those 'laid down in the delegated acts adopted pursuant to Article 4'; Art. 9(2) says those acts 'shall … specify' what a passport carries; and Art. 27 binds manufacturers only 'when placing products COVERED BY a delegated act adopted pursuant to Article 4' on the market. All three defer to an Art. 4 act, and none is adopted for this category — so this field is anticipated, not required. Verified against the EUR-Lex text."
+        "description": "ESPR 32024R1781 mandates no product data of its own. Art. 7(1) makes information requirements those 'laid down in the delegated acts adopted pursuant to Article 4'; Art. 9(2) says those acts 'shall … specify' what a passport carries; and Art. 27 binds manufacturers only 'when placing products COVERED BY a delegated act adopted pursuant to Article 4' on the market. All three defer to an Art. 4 act, and none is adopted for this category — and none is scheduled: the ESPR working plan COM(2025) 187 leaves paints out — so this field is optional. Verified against the EUR-Lex text."
       },
       "aiHints": {
         "alternateNames": [
@@ -6085,7 +6064,7 @@
         "instrument": "32024R1781",
         "provision": "Article 7(2)(c)",
         "kind": "legislation",
-        "description": "ESPR 32024R1781 mandates no product data of its own. Art. 7(1) makes information requirements those 'laid down in the delegated acts adopted pursuant to Article 4'; Art. 9(2) says those acts 'shall … specify' what a passport carries; and Art. 27 binds manufacturers only 'when placing products COVERED BY a delegated act adopted pursuant to Article 4' on the market. All three defer to an Art. 4 act, and none is adopted for this category — so this field is anticipated, not required. Verified against the EUR-Lex text."
+        "description": "ESPR 32024R1781 mandates no product data of its own. Art. 7(1) makes information requirements those 'laid down in the delegated acts adopted pursuant to Article 4'; Art. 9(2) says those acts 'shall … specify' what a passport carries; and Art. 27 binds manufacturers only 'when placing products COVERED BY a delegated act adopted pursuant to Article 4' on the market. All three defer to an Art. 4 act, and none is adopted for this category — and none is scheduled: the ESPR working plan COM(2025) 187 leaves paints out — so this field is optional. Verified against the EUR-Lex text."
       },
       "aiHints": {
         "alternateNames": [
@@ -6382,10 +6361,7 @@
         }
       ],
       "validation": {
-        "required": false,
-        "anticipated": true,
-        "anticipatedUnder": "32024R1781",
-        "anticipatedNote": "ESPR Art. 9(3) requires a data carrier for the DPP, but only once a chemicals delegated act applies; not in force."
+        "required": false
       },
       "category": "data_carrier",
       "categoryLabel": {
@@ -6421,7 +6397,7 @@
         "instrument": "32024R1781",
         "provision": "Article 9(3)",
         "kind": "legislation",
-        "description": "ESPR 32024R1781 mandates no product data of its own. Art. 7(1) makes information requirements those 'laid down in the delegated acts adopted pursuant to Article 4'; Art. 9(2) says those acts 'shall … specify' what a passport carries; and Art. 27 binds manufacturers only 'when placing products COVERED BY a delegated act adopted pursuant to Article 4' on the market. All three defer to an Art. 4 act, and none is adopted for this category — so this field is anticipated, not required. Verified against the EUR-Lex text."
+        "description": "ESPR 32024R1781 mandates no product data of its own. Art. 7(1) makes information requirements those 'laid down in the delegated acts adopted pursuant to Article 4'; Art. 9(2) says those acts 'shall … specify' what a passport carries; and Art. 27 binds manufacturers only 'when placing products COVERED BY a delegated act adopted pursuant to Article 4' on the market. All three defer to an Art. 4 act, and none is adopted for this category — and none is scheduled: the ESPR working plan COM(2025) 187 leaves paints out — so this field is optional. Verified against the EUR-Lex text."
       },
       "aiHints": {
         "alternateNames": [
@@ -6493,10 +6469,7 @@
       "defaultValue": null,
       "enumOptions": [],
       "validation": {
-        "required": false,
-        "anticipated": true,
-        "anticipatedUnder": "32024R1781",
-        "anticipatedNote": "ESPR Art. 9(3) data-carrier link is anticipated under a chemicals delegated act; not in force. GS1 Digital Link is a standard, not law."
+        "required": false
       },
       "category": "data_carrier",
       "categoryLabel": {
@@ -6532,7 +6505,7 @@
         "instrument": "32024R1781",
         "provision": "Article 9(3), GS1 Digital Link",
         "kind": "legislation",
-        "description": "ESPR 32024R1781 mandates no product data of its own. Art. 7(1) makes information requirements those 'laid down in the delegated acts adopted pursuant to Article 4'; Art. 9(2) says those acts 'shall … specify' what a passport carries; and Art. 27 binds manufacturers only 'when placing products COVERED BY a delegated act adopted pursuant to Article 4' on the market. All three defer to an Art. 4 act, and none is adopted for this category — so this field is anticipated, not required. Verified against the EUR-Lex text."
+        "description": "ESPR 32024R1781 mandates no product data of its own. Art. 7(1) makes information requirements those 'laid down in the delegated acts adopted pursuant to Article 4'; Art. 9(2) says those acts 'shall … specify' what a passport carries; and Art. 27 binds manufacturers only 'when placing products COVERED BY a delegated act adopted pursuant to Article 4' on the market. All three defer to an Art. 4 act, and none is adopted for this category — and none is scheduled: the ESPR working plan COM(2025) 187 leaves paints out — so this field is optional. Verified against the EUR-Lex text."
       },
       "aiHints": {
         "alternateNames": [
@@ -6604,10 +6577,7 @@
       "defaultValue": null,
       "enumOptions": [],
       "validation": {
-        "required": false,
-        "anticipated": true,
-        "anticipatedUnder": "32024R1781",
-        "anticipatedNote": "DPP validity metadata flows from the ESPR Art. 10 DPP regime; binds no chemicals product until a delegated act applies."
+        "required": false
       },
       "category": "data_carrier",
       "categoryLabel": {
@@ -6643,7 +6613,7 @@
         "instrument": "32024R1781",
         "provision": "Article 10",
         "kind": "legislation",
-        "description": "ESPR Art. 10 governs the passport's TECHNICAL design — data carrier, unique identifiers, access rights, availability — not which product data must be published. The substantive obligation still arrives via an Art. 4 delegated act, and none is adopted for this category. Anticipated; voluntary today. Verified against the EUR-Lex text."
+        "description": "ESPR Art. 10 governs the passport's TECHNICAL design — data carrier, unique identifiers, access rights, availability — not which product data must be published. The substantive obligation still arrives via an Art. 4 delegated act, and none is adopted for this category. None is scheduled either: the ESPR working plan COM(2025) 187 leaves paints out. Optional. Verified against the EUR-Lex text."
       },
       "aiHints": {
         "alternateNames": [
@@ -6715,10 +6685,7 @@
       "defaultValue": 10,
       "enumOptions": [],
       "validation": {
-        "required": false,
-        "anticipated": true,
-        "anticipatedUnder": "32024R1781",
-        "anticipatedNote": "Retention period is set by the future ESPR delegated act / Art. 10 regime; the '10 years' default is not an in-force chemicals obligation."
+        "required": false
       },
       "category": "data_carrier",
       "categoryLabel": {
@@ -6754,7 +6721,7 @@
         "instrument": "32024R1781",
         "provision": "Article 10(3)",
         "kind": "legislation",
-        "description": "ESPR Art. 10 governs the passport's TECHNICAL design — data carrier, unique identifiers, access rights, availability — not which product data must be published. The substantive obligation still arrives via an Art. 4 delegated act, and none is adopted for this category. Anticipated; voluntary today. Verified against the EUR-Lex text."
+        "description": "ESPR Art. 10 governs the passport's TECHNICAL design — data carrier, unique identifiers, access rights, availability — not which product data must be published. The substantive obligation still arrives via an Art. 4 delegated act, and none is adopted for this category. None is scheduled either: the ESPR working plan COM(2025) 187 leaves paints out. Optional. Verified against the EUR-Lex text."
       },
       "aiHints": {
         "alternateNames": [
@@ -6914,10 +6881,7 @@
         }
       ],
       "validation": {
-        "required": false,
-        "anticipated": true,
-        "anticipatedUnder": "32024R1781",
-        "anticipatedNote": "Access-rights tiering is part of the ESPR Art. 10 DPP regime, specified per group by the delegated act; not in force for chemicals."
+        "required": false
       },
       "category": "data_carrier",
       "categoryLabel": {
@@ -6953,7 +6917,7 @@
         "instrument": "32024R1781",
         "provision": "Article 10(4)",
         "kind": "legislation",
-        "description": "ESPR Art. 10 governs the passport's TECHNICAL design — data carrier, unique identifiers, access rights, availability — not which product data must be published. The substantive obligation still arrives via an Art. 4 delegated act, and none is adopted for this category. Anticipated; voluntary today. Verified against the EUR-Lex text."
+        "description": "ESPR Art. 10 governs the passport's TECHNICAL design — data carrier, unique identifiers, access rights, availability — not which product data must be published. The substantive obligation still arrives via an Art. 4 delegated act, and none is adopted for this category. None is scheduled either: the ESPR working plan COM(2025) 187 leaves paints out. Optional. Verified against the EUR-Lex text."
       },
       "aiHints": {
         "alternateNames": [