@tracepass/dpp-schemas 1.10.6 → 1.10.7

package/templates/steel.json

@@ -493,7 +493,7 @@
         "annex": null,
         "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 an iron and steel delegated act is scheduled (ESPR working plan COM(2025) 187: 2026; aluminium 2027), but whether it will require this datum is not known — so this field is optional. Verified against the EUR-Lex text."
       },
       "aiHints": {
         "alternateNames": [
@@ -2262,7 +2262,7 @@
         "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 an iron and steel delegated act is scheduled (ESPR working plan COM(2025) 187: 2026; aluminium 2027), but whether it will require this datum is not known — so this field is optional. Verified against the EUR-Lex text."
       },
       "aiHints": {
         "alternateNames": [
@@ -2957,7 +2957,7 @@
         "annex": null,
         "instrument": null,
         "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 an iron and steel delegated act is scheduled (ESPR working plan COM(2025) 187: 2026; aluminium 2027), but whether it will require this datum is not known — so this field is optional. Verified against the EUR-Lex text.",
         "standards": [
           "ISO 14021"
         ]
@@ -3071,7 +3071,7 @@
         "annex": null,
         "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 an iron and steel delegated act is scheduled (ESPR working plan COM(2025) 187: 2026; aluminium 2027), but whether it will require this datum is not known — so this field is optional. Verified against the EUR-Lex text."
       },
       "aiHints": {
         "alternateNames": [
@@ -3297,7 +3297,7 @@
         "annex": null,
         "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 an iron and steel delegated act is scheduled (ESPR working plan COM(2025) 187: 2026; aluminium 2027), but whether it will require this datum is not known — so this field is optional. Verified against the EUR-Lex text."
       },
       "aiHints": {
         "alternateNames": [
@@ -3405,7 +3405,7 @@
         "annex": null,
         "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 an iron and steel delegated act is scheduled (ESPR working plan COM(2025) 187: 2026; aluminium 2027), but whether it will require this datum is not known — so this field is optional. Verified against the EUR-Lex text."
       },
       "aiHints": {
         "alternateNames": [
@@ -5034,30 +5034,30 @@
         "sv": "Elnätets koldioxidintensitet"
       },
       "description": {
-        "en": "Grid emission factor in gCO2/kWh. Critical for aluminium indirect emissions calculation under CBAM.",
-        "bg": "Коефициент на емисии на мрежата в gCO2/kWh. От съществено значение за изчисляването на косвените емисии от алуминий по CBAM.",
-        "de": "Netzemissionsfaktor in gCO2/kWh. Entscheidend für die Berechnung der indirekten Emissionen von Aluminium im Rahmen von CBAM.",
-        "hr": "Faktor emisije mreže u gCO2/kWh. Kritično za izračun indirektnih emisija aluminija prema CBAM.",
-        "cs": "Emisní faktor sítě v gCO2/kWh. Klíčový pro výpočet nepřímých emisí hliníku v rámci CBAM.",
-        "da": "Nettets emissionsfaktor i gCO2/kWh. Kritisk for beregning af aluminiums indirekte emissioner under CBAM.",
-        "nl": "Emissiefactor net in gCO2/kWh. Essentieel voor berekening van indirecte aluminiumemissies onder CBAM.",
-        "et": "Võrgu heitetegur gCO2/kWh. Kriitiline alumiiniumi kaudsete heidete arvutamiseks CBAM-i raames.",
-        "fi": "Verkon päästökerroin gCO2/kWh. Kriittinen alumiinin epäsuorien päästöjen laskentaan CBAM:n alla.",
-        "fr": "Facteur d'émission du réseau en gCO2/kWh. Essentiel pour le calcul des émissions indirectes de l'aluminium sous CBAM.",
-        "el": "Συντελεστής εκπομπών δικτύου σε gCO2/kWh. Κρίσιμος για τον υπολογισμό των έμμεσων εκπομπών αλουμινίου υπό CBAM.",
-        "hu": "Hálózati kibocsátási tényező gCO2/kWh-ban. Kritikus az alumínium közvetett kibocsátásainak számításához CBAM alatt.",
-        "ga": "Fachtóir astaíochtaí eangaí i gCO2/kWh. Ríthábhachtach chun astaíochtaí indíreacha alúmanaim a ríomh faoi CBAM.",
-        "it": "Fattore di emissione della rete in gCO2/kWh. Fondamentale per il calcolo delle emissioni indirette dell'alluminio nell'ambito CBAM.",
-        "es": "Factor de emisión de la red en gCO2/kWh. Crítico para el cálculo de emisiones indirectas de aluminio conforme al CBAM.",
-        "lt": "Tinklo išmetamųjų teršalų faktorius gCO2/kWh. Svarbus skaičiuojant netiesiogines aliuminio emisijas pagal CBAM.",
-        "lv": "Tīkla emisiju faktors gCO2/kWh. Būtisks alumīnija netiešo emisiju aprēķinam saskaņā ar CBAM.",
-        "mt": "Fattur tal-emissjonijiet tal-grid f'gCO2/kWh. Kritiku għall-kalkolu tal-emissjonijiet indiretti tal-aluminju taħt CBAM.",
-        "pl": "Wskaźnik emisji sieci w gCO2/kWh. Kluczowy dla obliczania emisji pośrednich aluminium w ramach CBAM.",
-        "pt": "Fator de emissão da rede em gCO2/kWh. Crítico para o cálculo de emissões indiretas do alumínio nos termos do CBAM.",
-        "ro": "Factor de emisie al rețelei în gCO2/kWh. Esențial pentru calcularea emisiilor indirecte de aluminiu în cadrul CBAM.",
-        "sk": "Emisný faktor siete v gCO2/kWh. Kľúčový pre výpočet nepriamych emisií hliníka podľa CBAM.",
-        "sl": "Emisijski faktor omrežja v gCO2/kWh. Ključen za izračun posrednih emisij aluminija v okviru CBAM.",
-        "sv": "Nätets emissionsfaktor i gCO2/kWh. Avgörande för beräkning av indirekta utsläpp för aluminium enligt CBAM."
+        "en": "Grid emission factor in gCO2/kWh.",
+        "bg": "Коефициент на емисии на мрежата в gCO2/kWh.",
+        "de": "Netzemissionsfaktor in gCO2/kWh.",
+        "hr": "Faktor emisije mreže u gCO2/kWh.",
+        "cs": "Emisní faktor sítě v gCO2/kWh.",
+        "da": "Nettets emissionsfaktor i gCO2/kWh.",
+        "nl": "Emissiefactor net in gCO2/kWh.",
+        "et": "Võrgu heitetegur gCO2/kWh.",
+        "fi": "Verkon päästökerroin gCO2/kWh.",
+        "fr": "Facteur d'émission du réseau en gCO2/kWh.",
+        "el": "Συντελεστής εκπομπών δικτύου σε gCO2/kWh.",
+        "hu": "Hálózati kibocsátási tényező gCO2/kWh-ban.",
+        "ga": "Fachtóir astaíochtaí eangaí i gCO2/kWh.",
+        "it": "Fattore di emissione della rete in gCO2/kWh.",
+        "es": "Factor de emisión de la red en gCO2/kWh.",
+        "lt": "Tinklo išmetamųjų teršalų faktorius gCO2/kWh.",
+        "lv": "Tīkla emisiju faktors gCO2/kWh.",
+        "mt": "Fattur tal-emissjonijiet tal-grid f'gCO2/kWh.",
+        "pl": "Wskaźnik emisji sieci w gCO2/kWh.",
+        "pt": "Fator de emissão da rede em gCO2/kWh.",
+        "ro": "Factor de emisie al rețelei în gCO2/kWh.",
+        "sk": "Emisný faktor siete v gCO2/kWh.",
+        "sl": "Emisijski faktor omrežja v gCO2/kWh.",
+        "sv": "Nätets emissionsfaktor i gCO2/kWh."
       },
       "dataType": "number",
       "unit": "gCO2/kWh",
@@ -5068,8 +5068,8 @@
         "required": false,
         "min": 0,
         "anticipated": true,
-        "anticipatedUnder": "32023R0956",
-        "anticipatedNote": "Grid emission factor is an input to CBAM indirect (Scope 2) emissions, which for iron/steel are NOT counted in the definitive CBAM (indirect only applies to some goods); relevant chiefly for aluminium."
+        "anticipatedUnder": "32024R1781",
+        "anticipatedNote": "CBAM counts only direct emissions for both iron and steel and aluminium (Annex II), so electricity data is not a CBAM data element for these goods. It is recorded as an input to the carbon footprint that the scheduled ESPR iron and steel delegated act (COM(2025) 187: 2026) may require; that act is not adopted."
       },
       "category": "production_data",
       "categoryLabel": {
@@ -5101,11 +5101,12 @@
       "sortOrder": 32,
       "defaultAccessLevel": "authority",
       "regulationRef": {
-        "article": "CBAM",
+        "article": "ESPR Art. 4 delegated act (not adopted); CBAM Annex II",
         "annex": null,
-        "instrument": "32023R0956",
+        "instrument": "32024R1781",
         "kind": "legislation",
-        "description": "A grid emission factor is an input to INDIRECT (Scope 2) emissions. Indirect emissions are not counted for iron and steel in the definitive CBAM regime — they matter chiefly for aluminium — and the reporting duty falls on the importing declarant in any case."
+        "description": "CBAM counts only direct emissions for both iron and steel and aluminium (Annex II), so electricity data is not a CBAM data element for these goods. It is recorded as an input to the carbon footprint that the scheduled ESPR iron and steel delegated act (COM(2025) 187: 2026) may require; that act is not adopted.",
+        "provision": "Art. 4"
       },
       "aiHints": {
         "alternateNames": [
@@ -5216,7 +5217,7 @@
         "annex": null,
         "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 an iron and steel delegated act is scheduled (ESPR working plan COM(2025) 187: 2026; aluminium 2027), but whether it will require this datum is not known — so this field is optional. Verified against the EUR-Lex text."
       },
       "aiHints": {
         "alternateNames": [
@@ -5291,8 +5292,8 @@
         "required": false,
         "min": 0,
         "anticipated": true,
-        "anticipatedUnder": "32023R0956",
-        "anticipatedNote": "Electricity consumption feeds indirect-emissions calc; excluded for iron/steel definitive CBAM, material for aluminium only."
+        "anticipatedUnder": "32024R1781",
+        "anticipatedNote": "CBAM counts only direct emissions for both iron and steel and aluminium (Annex II), so electricity data is not a CBAM data element for these goods. It is recorded as an input to the carbon footprint that the scheduled ESPR iron and steel delegated act (COM(2025) 187: 2026) may require; that act is not adopted."
       },
       "category": "production_data",
       "categoryLabel": {
@@ -5324,11 +5325,12 @@
       "sortOrder": 34,
       "defaultAccessLevel": "authority",
       "regulationRef": {
-        "article": "CBAM",
+        "article": "ESPR Art. 4 delegated act (not adopted); CBAM Annex II",
         "annex": null,
-        "instrument": "32023R0956",
+        "instrument": "32024R1781",
         "kind": "legislation",
-        "description": "Electricity consumption feeds the indirect-emissions calculation, which the definitive CBAM excludes for iron and steel. Material for aluminium; not a mandated steel datum, and the duty holder is the importer."
+        "description": "CBAM counts only direct emissions for both iron and steel and aluminium (Annex II), so electricity data is not a CBAM data element for these goods. It is recorded as an input to the carbon footprint that the scheduled ESPR iron and steel delegated act (COM(2025) 187: 2026) may require; that act is not adopted.",
+        "provision": "Art. 4"
       },
       "aiHints": {
         "alternateNames": [
@@ -5437,7 +5439,7 @@
         "annex": null,
         "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 an iron and steel delegated act is scheduled (ESPR working plan COM(2025) 187: 2026; aluminium 2027), but whether it will require this datum is not known — so this field is optional. Verified against the EUR-Lex text."
       },
       "aiHints": {
         "alternateNames": [
@@ -6294,7 +6296,7 @@
         "annex": null,
         "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 an iron and steel delegated act is scheduled (ESPR working plan COM(2025) 187: 2026; aluminium 2027), but whether it will require this datum is not known — so this field is optional. Verified against the EUR-Lex text."
       },
       "aiHints": {
         "alternateNames": [
@@ -7120,7 +7122,7 @@
         "instrument": "32024R1781",
         "provision": "Article 7",
         "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. Reference: Performance classes via delegated act."
+        "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 an iron and steel delegated act is scheduled (ESPR working plan COM(2025) 187: 2026; aluminium 2027), but whether it will require this datum is not known — so this field is optional. Verified against the EUR-Lex text. Reference: Performance classes via delegated act."
       },
       "aiHints": {
         "alternateNames": [
@@ -7816,10 +7818,7 @@
       "defaultValue": null,
       "enumOptions": null,
       "validation": {
-        "required": false,
-        "anticipated": true,
-        "anticipatedUnder": "32023R0956",
-        "anticipatedNote": "CBAM Art. 9 lets an importer DEDUCT a carbon price paid abroad; supplying it is optional (to reduce certificates), not a mandated data element."
+        "required": false
       },
       "category": "cbam",
       "categoryLabel": {
@@ -7856,7 +7855,7 @@
         "instrument": "32023R0956",
         "provision": "Article 9",
         "kind": "legislation",
-        "description": "CBAM Art. 9 lets an authorised declarant claim a REDUCTION for a carbon price already paid in the country of origin. Supplying the figure serves the importer's interest in surrendering fewer certificates; it is an optional claim, not a mandated disclosure."
+        "description": "CBAM Art. 9 lets an authorised declarant claim a REDUCTION for a carbon price already paid in the country of origin. Supplying the figure serves the importer's interest in surrendering fewer certificates; it is an optional claim, not a mandated disclosure. No act requiring it in a product passport is adopted or scheduled, so this field is optional."
       },
       "aiHints": {
         "alternateNames": [
@@ -9503,7 +9502,7 @@
         "instrument": "32024R1781",
         "provision": "Article 5(5)(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": "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 an iron and steel delegated act is scheduled (ESPR working plan COM(2025) 187: 2026; aluminium 2027), but whether it will require this datum is not known — so this field is optional. Verified against the EUR-Lex text."
       },
       "aiHints": {
         "alternateNames": [
@@ -9616,7 +9615,7 @@
         "instrument": "32024R1781",
         "provision": "Article 5(5)(i)",
         "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 an iron and steel delegated act is scheduled (ESPR working plan COM(2025) 187: 2026; aluminium 2027), but whether it will require this datum is not known — so this field is optional. Verified against the EUR-Lex text."
       },
       "aiHints": {
         "alternateNames": [
@@ -9725,7 +9724,7 @@
         "instrument": "32024R1781",
         "provision": "Article 5(5)(l)",
         "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 an iron and steel delegated act is scheduled (ESPR working plan COM(2025) 187: 2026; aluminium 2027), but whether it will require this datum is not known — so this field is optional. Verified against the EUR-Lex text."
       },
       "aiHints": {
         "alternateNames": [
@@ -11156,7 +11155,7 @@
         "instrument": "32024R1781",
         "provision": "Article 5(5)(o)",
         "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. Reference: GS1 EPCIS 2.0."
+        "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 an iron and steel delegated act is scheduled (ESPR working plan COM(2025) 187: 2026; aluminium 2027), but whether it will require this datum is not known — so this field is optional. Verified against the EUR-Lex text. Reference: GS1 EPCIS 2.0."
       },
       "aiHints": {
         "alternateNames": [

package/templates/toys.json

@@ -3698,10 +3698,7 @@
       "defaultValue": null,
       "enumOptions": null,
       "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": "materials",
       "categoryLabel": {
@@ -3735,7 +3732,7 @@
       "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 (toys are not in the ESPR working plan COM(2025) 187); the toy passport under Reg. (EU) 2025/2509 Annex VI Part I does not list this datum — so this field is optional. Verified against the EUR-Lex text."
       },
       "aiHints": {
         "alternateNames": [
@@ -4262,10 +4259,7 @@
       "defaultValue": null,
       "enumOptions": null,
       "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": {
@@ -4299,7 +4293,7 @@
       "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 (toys are not in the ESPR working plan COM(2025) 187); the toy passport under Reg. (EU) 2025/2509 Annex VI Part I does not list this datum — so this field is optional. Verified against the EUR-Lex text."
       },
       "aiHints": {
         "alternateNames": [
@@ -4461,10 +4455,7 @@
         }
       ],
       "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": {
@@ -4498,7 +4489,7 @@
       "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 (toys are not in the ESPR working plan COM(2025) 187); the toy passport under Reg. (EU) 2025/2509 Annex VI Part I does not list this datum — so this field is optional. Verified against the EUR-Lex text."
       },
       "aiHints": {
         "alternateNames": [
@@ -4679,10 +4670,7 @@
       "defaultValue": null,
       "enumOptions": null,
       "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": {
@@ -4716,7 +4704,7 @@
       "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 (toys are not in the ESPR working plan COM(2025) 187); the toy passport under Reg. (EU) 2025/2509 Annex VI Part I does not list this datum — so this field is optional. Verified against the EUR-Lex text."
       },
       "aiHints": {
         "alternateNames": [
@@ -4790,10 +4778,7 @@
       "defaultValue": null,
       "enumOptions": null,
       "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": "durability",
       "categoryLabel": {
@@ -4827,7 +4812,7 @@
       "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 (toys are not in the ESPR working plan COM(2025) 187); the toy passport under Reg. (EU) 2025/2509 Annex VI Part I does not list this datum — so this field is optional. Verified against the EUR-Lex text."
       },
       "aiHints": {
         "alternateNames": [
@@ -4901,10 +4886,7 @@
       "defaultValue": null,
       "enumOptions": null,
       "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": "durability",
       "categoryLabel": {
@@ -4938,7 +4920,7 @@
       "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 (toys are not in the ESPR working plan COM(2025) 187); the toy passport under Reg. (EU) 2025/2509 Annex VI Part I does not list this datum — so this field is optional. Verified against the EUR-Lex text."
       },
       "aiHints": {
         "alternateNames": [
@@ -5122,10 +5104,7 @@
       "defaultValue": null,
       "enumOptions": null,
       "validation": {
-        "required": false,
-        "anticipated": true,
-        "anticipatedUnder": "32024R1781",
-        "anticipatedNote": "Anticipated DPP content under ESPR Art. 9(2)/Annex III"
+        "required": false
       },
       "category": "supply_chain",
       "categoryLabel": {
@@ -5161,7 +5140,7 @@
         "instrument": "32024R1781",
         "provision": "Art. 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 (toys are not in the ESPR working plan COM(2025) 187); the toy passport under Reg. (EU) 2025/2509 Annex VI Part I does not list this datum — so this field is optional. Verified against the EUR-Lex text."
       },
       "aiHints": {
         "alternateNames": [

package/templates/tyres.json

@@ -712,7 +712,7 @@
         "instrument": "32024R1781",
         "provision": "Art. 9(2)",
         "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 a tyres delegated act is scheduled (ESPR working plan COM(2025) 187: 2027), but whether it will require this datum is not known — so this field is optional. Verified against the EUR-Lex text."
       },
       "aiHints": {
         "alternateNames": [
@@ -820,7 +820,7 @@
         "instrument": "32024R1781",
         "provision": "Art. 9(2)",
         "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 a tyres delegated act is scheduled (ESPR working plan COM(2025) 187: 2027), but whether it will require this datum is not known — so this field is optional. Verified against the EUR-Lex text."
       },
       "aiHints": {
         "alternateNames": [
@@ -6707,7 +6707,7 @@
         "instrument": "32024R1781",
         "provision": "Art. 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 a tyres delegated act is scheduled (ESPR working plan COM(2025) 187: 2027), but whether it will require this datum is not known — so this field is optional. Verified against the EUR-Lex text."
       },
       "aiHints": {
         "alternateNames": [
@@ -6815,7 +6815,7 @@
         "instrument": "32024R1781",
         "provision": "Art. 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 a tyres delegated act is scheduled (ESPR working plan COM(2025) 187: 2027), but whether it will require this datum is not known — so this field is optional. Verified against the EUR-Lex text."
       },
       "aiHints": {
         "alternateNames": [
@@ -6923,7 +6923,7 @@
         "instrument": "32024R1781",
         "provision": "Art. 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 a tyres delegated act is scheduled (ESPR working plan COM(2025) 187: 2027), but whether it will require this datum is not known — so this field is optional. Verified against the EUR-Lex text."
       },
       "aiHints": {
         "alternateNames": [