@tracepass/dpp-schemas 1.10.6 → 1.11.0

package/templates/detergents.json

@@ -214,10 +214,7 @@
       "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": {
@@ -253,7 +250,7 @@
         "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 detergents out); the detergents passport under Reg. (EU) 2026/405 Annex VI does not list this datum — so this field is optional. Verified against the EUR-Lex text."
       },
       "aiHints": {
         "alternateNames": [
@@ -479,7 +476,7 @@
         "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 detergents out); the detergents passport under Reg. (EU) 2026/405 Annex VI does not list this datum — so this field is optional. Verified against the EUR-Lex text."
       },
       "aiHints": {
         "alternateNames": [
@@ -704,7 +701,7 @@
         "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 detergents out); the detergents passport under Reg. (EU) 2026/405 Annex VI does not list this datum — so this field is optional. Verified against the EUR-Lex text."
       },
       "aiHints": {
         "alternateNames": [
@@ -1303,10 +1300,7 @@
         }
       ],
       "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": {
@@ -1342,7 +1336,7 @@
         "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 detergents out); the detergents passport under Reg. (EU) 2026/405 Annex VI does not list this datum — so this field is optional. Verified against the EUR-Lex text."
       },
       "aiHints": {
         "alternateNames": [
@@ -1625,7 +1619,7 @@
         "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 detergents out); the detergents passport under Reg. (EU) 2026/405 Annex VI does not list this datum — so this field is optional. Verified against the EUR-Lex text."
       },
       "aiHints": {
         "alternateNames": [
@@ -2789,7 +2783,7 @@
         "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 detergents out); the detergents passport under Reg. (EU) 2026/405 Annex VI does not list this datum — so this field is optional. Verified against the EUR-Lex text."
       },
       "aiHints": {
         "alternateNames": [
@@ -2861,10 +2855,7 @@
       "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": {
@@ -2900,7 +2891,7 @@
         "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 detergents out); the detergents passport under Reg. (EU) 2026/405 Annex VI does not list this datum — so this field is optional. Verified against the EUR-Lex text."
       },
       "aiHints": {
         "alternateNames": [
@@ -4836,7 +4827,7 @@
         "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 detergents out); the detergents passport under Reg. (EU) 2026/405 Annex VI does not list this datum — so this field is optional. Verified against the EUR-Lex text."
       },
       "aiHints": {
         "alternateNames": [
@@ -5795,7 +5786,7 @@
         "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 detergents out); the detergents passport under Reg. (EU) 2026/405 Annex VI does not list this datum — so this field is optional. Verified against the EUR-Lex text."
       },
       "aiHints": {
         "alternateNames": [
@@ -5962,7 +5953,7 @@
         "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 detergents out); the detergents passport under Reg. (EU) 2026/405 Annex VI does not list this datum — so this field is optional. Verified against the EUR-Lex text."
       },
       "aiHints": {
         "alternateNames": [
@@ -6069,7 +6060,7 @@
         "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 detergents out); the detergents passport under Reg. (EU) 2026/405 Annex VI does not list this datum — so this field is optional. Verified against the EUR-Lex text."
       },
       "aiHints": {
         "alternateNames": [
@@ -6141,10 +6132,7 @@
       "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": {
@@ -6178,7 +6166,7 @@
       "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 detergents out); the detergents passport under Reg. (EU) 2026/405 Annex VI does not list this datum — so this field is optional. Verified against the EUR-Lex text."
       },
       "aiHints": {
         "alternateNames": [
@@ -6285,7 +6273,7 @@
         "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 detergents out); the detergents passport under Reg. (EU) 2026/405 Annex VI does not list this datum — so this field is optional. Verified against the EUR-Lex text."
       },
       "aiHints": {
         "alternateNames": [
@@ -6584,8 +6572,8 @@
       "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."
+        "anticipatedUnder": "32026R0405",
+        "anticipatedNote": "Reg. (EU) 2026/405 Art. 21(2)(h) and 21(4) require the passport to be reached through a data carrier linked to a persistent unique product identifier; the carrier's technical requirements come from the Art. 21(10) implementing act, which is not adopted."
       },
       "category": "data_carrier",
       "categoryLabel": {
@@ -6617,11 +6605,11 @@
       "sortOrder": 60,
       "defaultAccessLevel": "public",
       "regulationRef": {
-        "article": "ESPR Art. 9(3)",
-        "instrument": "32024R1781",
-        "provision": "Article 9(3)",
+        "article": "Detergents Regulation Art. 21(2)(h), (4)",
+        "instrument": "32026R0405",
+        "provision": "Art. 21(2)(h), (4)",
         "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": "Reg. (EU) 2026/405 Art. 21(2)(h) and 21(4) require the passport to be reached through a data carrier linked to a persistent unique product identifier; the carrier's technical requirements come from the Art. 21(10) implementing act, which is not adopted."
       },
       "aiHints": {
         "alternateNames": [
@@ -6695,8 +6683,8 @@
       "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."
+        "anticipatedUnder": "32026R0405",
+        "anticipatedNote": "Reg. (EU) 2026/405 Art. 21(2)(h) and 21(4) require the passport to be reached through a data carrier linked to a persistent unique product identifier; the carrier's technical requirements come from the Art. 21(10) implementing act, which is not adopted."
       },
       "category": "data_carrier",
       "categoryLabel": {
@@ -6728,11 +6716,11 @@
       "sortOrder": 61,
       "defaultAccessLevel": "public",
       "regulationRef": {
-        "article": "ESPR Art. 9(3), GS1 Digital Link",
-        "instrument": "32024R1781",
-        "provision": "Article 9(3), GS1 Digital Link",
+        "article": "Detergents Regulation Art. 21(2)(h)",
+        "instrument": "32026R0405",
+        "provision": "Art. 21(2)(h)",
         "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": "Reg. (EU) 2026/405 Art. 21(2)(h) and 21(4) require the passport to be reached through a data carrier linked to a persistent unique product identifier; the carrier's technical requirements come from the Art. 21(10) implementing act, which is not adopted. GS1 Digital Link is one implementation, not a legal requirement."
       },
       "aiHints": {
         "alternateNames": [
@@ -6804,10 +6792,7 @@
       "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": {
@@ -6843,7 +6828,7 @@
         "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 detergents out, and Reg. (EU) 2026/405 Annex VI does not list this datum. Optional. Verified against the EUR-Lex text."
       },
       "aiHints": {
         "alternateNames": [
@@ -6915,10 +6900,7 @@
       "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": {
@@ -6950,11 +6932,11 @@
       "sortOrder": 63,
       "defaultAccessLevel": "public",
       "regulationRef": {
-        "article": "ESPR Art. 10(3)",
-        "instrument": "32024R1781",
-        "provision": "Article 10(3)",
+        "article": "Detergents Regulation Art. 21(2)(g)",
+        "instrument": "32026R0405",
+        "provision": "Art. 21(2)(g)",
         "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": "Reg. (EU) 2026/405 Art. 21(2)(g) fixes passport availability at 10 years from placing on the market (applies from 23 September 2029). It is a period the law sets, not a datum to supply, so this field is optional."
       },
       "aiHints": {
         "alternateNames": [
@@ -7116,8 +7098,8 @@
       "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."
+        "anticipatedUnder": "32026R0405",
+        "anticipatedNote": "Reg. (EU) 2026/405 Art. 21(2)(f) makes passport access follow the access rights the Art. 21(10)(d) implementing act will lay down; that act is not adopted."
       },
       "category": "data_carrier",
       "categoryLabel": {
@@ -7149,11 +7131,11 @@
       "sortOrder": 64,
       "defaultAccessLevel": "public",
       "regulationRef": {
-        "article": "ESPR Art. 10(4)",
-        "instrument": "32024R1781",
-        "provision": "Article 10(4)",
+        "article": "Detergents Regulation Art. 21(2)(f)",
+        "instrument": "32026R0405",
+        "provision": "Art. 21(2)(f)",
         "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": "Reg. (EU) 2026/405 Art. 21(2)(f) makes passport access follow the access rights the Art. 21(10)(d) implementing act will lay down; that act is not adopted."
       },
       "aiHints": {
         "alternateNames": [