v0.99.8.1: mandatory certificate rules become date-aware
Completes the date-aware enforcement work from v0.99.8.0 by extending it to mandatory certificate rules. Two certificate requirements whose obligations the Regulation has not yet brought into force no longer block publication.
Certificates now follow the same timeline as fields
v0.99.8.0 made five field surfaces date-aware, but the certificate check was a separate code path with no notion of dates. A customer reported the consequence directly: the Due Diligence Report and Carbon Footprint Verification certificates were both marked mandatory even though neither obligation has reached its compliance date.
Exactly two certificate requirements are affected:
| Certificate | Categories | Basis | Binds from |
|---|---|---|---|
| Carbon Footprint Verification | LMT, industrial, stationary | Regulation (EU) 2023/1542 Art. 7 | 18 Aug 2028 (LMT), 18 Feb 2028 (industrial and stationary) |
| Due Diligence Report | EV, LMT, industrial, stationary | Annex XIII §5 / Art. 48, postponed by Regulation (EU) 2025/1561 | 18 Aug 2027 |
Everything else still blocks, and nothing was made optional:
- EV Carbon Footprint Verification still blocks. That obligation has been in force since 18 February 2025.
- UN 38.3, REACH Declaration, CE Declaration of Conformity, CE Marking Declaration, and IEC 62133-2 all still block. They are in force today.
- Industrial batteries at or below 2 kWh continue to block on carbon footprint, because their exclusion is a scope question rather than a date question.
- An unknown or unresolvable battery category fails closed and keeps blocking.
A certificate that is not yet mandatory is not hidden. It stays in your document requirements with a "Mandatory from [date]" label, so you can see what is coming and prepare rather than being surprised when the date arrives.
See Documents for the full table of which certificate requirements are in force today.