jouleclaw-compliance: no ESPR record on an AI service passport #441

Merged
dcharlot merged 1 commit from fix/passport-no-espr into main 2026-11-01 09:38:43 -05:00

2026-10-22

Transaction Science
jouleclaw-compliance: no ESPR record on an AI service passport
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The AI Service Passport's compliance record carried an ESPR digital product
passport with a bare `registry_submitted: bool`. ESPR applies to physical
goods placed on the market or put into service (Regulation (EU) 2024/1781,
Art. 1(2)); a passport here describes a service, so the record claimed a
regime that cannot apply, under a flag nothing checked. It is removed. The
hardware a service runs on is a physical good, and its passport, where a
delegated act requires one, is the hardware's.

A passport written with the record still reads, and the member is dropped.
A seal taken over the old shape does not re-derive from what is read; the
record's doc says to check it against the original bytes.

EsprReport, a product-shaped report, now says it is for a physical product
rather than "product / model".

Co-Authored-By: Claude Opus 5.5 <[email protected]>
2026-10-22 07:26:53 -04:00