The EU Digital Product Passport Registry Is Now Live: What Businesses Need to Know About Registration
On 20 July 2026, the European Commission switched on the Digital Product Passport Registry, along with a testing environment businesses can use to get familiar with it before registration becomes mandatory for their product category. For the past couple of years, the Digital Product Passport has mostly existed as a concept on paper: a future requirement tied to the Ecodesign for Sustainable Products Regulation (ESPR) that businesses knew was coming but couldn’t fully act on. That’s changed. That’s changed. There is now a live system and a real enrolment process that organisations can complete today, even though registering individual product passports is only being switched on gradually, one product category at a time.
If your products fall under ESPR or one of the related regulations (batteries, construction products, toys, detergents), this is the point where DPP compliance stops being theoretical.
What Is the EU Digital Product Passport Registry?
It helps to separate two things that get lumped together: the Digital Product Passport itself, and the DPP Registry.
The Digital Product Passport is the full record of information about a product: its materials, where it was made, how to repair it, how to recycle it, and so on. That data isn’t held by the EU. It sits with the economic operator responsible for the product, or with a service provider hosting it on their behalf.
The Registry is different. It’s a central EU-level database that holds a much thinner slice of information: a unique identifier for each product, some registration data, and high-level metadata. Think of it less as a filing cabinet full of product documents and more as an index that says “this product exists, it’s registered, and here’s where to find its full passport.” The Commission has been explicit that the Registry does not store the detailed product data itself.
That structure is intentional. The DPP system is built to be decentralised at the data level but centralised at the identifier level, so that customs officers, market surveillance authorities, and businesses across different countries are all pointing to the same reference system rather than dozens of incompatible ones.
Why the EU Created the Digital Product Passport Registry
Without a shared registry, there’s no reliable way to check, at scale, whether a product entering the EU actually has a valid passport behind it. The Registry solves that in a few concrete ways.
Customs authorities will be able to run an electronic check at the border to confirm an imported product has a registered DPP and the right commodity code before releasing it for free circulation. Market surveillance authorities get a consistent way to pull up registered passports when they’re investigating a product. And businesses get a single, standardised place to register, rather than each Member State running its own version.
The Registry also hosts a semantic repository: shared data models, definitions, and vocabulary that different companies and software providers can build against. That matters more than it sounds, because it’s what stops the DPP system from turning into a mess of incompatible formats once thousands of businesses start registering products across dozens of sectors.
How to Register a Digital Product Passport (Step by Step)
Based on the Commission’s DPP Registry User Guide for Economic Operators (v1.03, September 2026), registration happens in two stages: first your organisation enrols, then you register individual passports.
Stage 1: Enrol your organisation
- Sign in with EU Login. The Registry uses the Commission’s EU Login system. If you don’t already have an account, you’ll create one during this step.
- Enter your organisation’s details. This includes your legal name, address, country of registration, and an organisation identifier (such as a VAT number, LEI, or national trade register number), plus a compliance contact. Individuals trading in their own name can also enrol, using a tax identification number or another accepted ID.
- Name a legal representative. You’ll give the name and email address of the person legally representing the organisation.
- Download, seal and upload the declaration. The Registry generates a PDF declaration sealed by the European Commission. You then sign or seal it outside the Registry and upload it again.
- Submit for verification and track the status. The Activity Dashboard shows whether your application is still processing, accepted, or rejected. Once you’re verified, the person who completed enrolment becomes the organisation’s Administrator and can manage users from there.
Stage 2: Register each Digital Product Passport
Once enrolled, you register each passport against its Unique Product Identifier (UPI). This is a URL-based identifier that must follow the relevant European standards, and it points to where the full passport is hosted. Model and batch identifiers can be added but are optional. Passports can be registered one at a time through an online form, or in bulk by uploading an XML or JSON file of up to 100 passports.
Where things stand right now: batteries are the only product group available in the Registry so far, and only at item level. Even for batteries, product registrations can’t be completed yet, because the Commission hasn’t finalised the data model (the “semantic catalogue”) for that product group. Other product groups will be added as their ecodesign requirements come into force.
A separate testing environment lets businesses practise enrolment and registration before it counts. It needs a different EU Login account from the one you use on the live Registry, and it uses the same verification process.
The Qualified Seal Requirement: The Step Most Businesses Aren’t Ready For
The part of enrolment most likely to hold businesses up is the signature on the declaration. An ordinary e-signature won’t be accepted. Companies need a qualified electronic seal (QSeal), and individuals need a qualified electronic signature (QES). Both must be issued by a Qualified Trust Service Provider (QTSP).
Owning a qualified certificate isn’t enough on its own. It has to be used either through a qualified signing device (a smart card or USB token supplied by your QTSP) or through a qualified remote signing service. The details in the certificate, such as organisation name, country and organisation identifier, must also exactly match what you entered in the Registry. A mismatch is one of the most common reasons applications get rejected.
These are paid services, and getting one set up can take time, so it’s worth arranging well before you plan to enrol.
Who Needs to Register in the DPP Registry?
Registration obligations fall on the economic operator placing the product on the EU market, whether it’s made inside the EU or imported. Depending on the product and supply chain, that could mean a manufacturer, an importer, an authorised representative, a distributor, a dealer, or a fulfilment service provider. If a product reaches EU customers through an online marketplace, that marketplace also has a role in making sure the passport is accessible.
In practice, most non-EU sellers won’t be registering products directly through their own EU legal entity. This is typically handled through whichever party is legally established in the EU on their behalf, which is exactly where representation arrangements become relevant.
Digital Product Passport Registry Deadlines by Product Category
DPP obligations are being phased in by product category rather than switched on across the board, and the dates matter a lot depending on what you sell.
Under the ESPR working plan, the indicative rollout looks like this:
- 2026 — Iron and steel
- 2026–2029 — Energy-related products (rolling basis)
- 2027 — Textiles, tyres, and aluminium
- 2028 — Furniture
- 2029 — Mattresses and ICT products
Once a delegated act for a product category is adopted, businesses get a transition period of at least 18 months before the obligation actually bites. So these dates aren’t cliff edges, but they’re also not that far off once you account for supply chain preparation time.
Outside the ESPR working plan, some categories are moving faster because they sit under their own dedicated legislation:
- Large batteries — certain categories become subject to mandatory passport requirements from 18 February 2027, currently the nearest hard deadline tied to the Registry.
- Construction products, toys, detergents, and end-user surfactants — also expected to require registration under their respective regulations, on timelines set separately from the ESPR working plan.
One more date worth flagging: the direct link between the Registry and customs systems is expected to take around four years to fully build out from the Registry’s launch, putting full customs integration around 2029. That doesn’t mean customs checks are absent before then, but the fully automated border verification is still a few years out.
Penalties for Non-Compliance with DPP Registration
Penalties are set at the Member State level rather than by the Commission directly, but the Ecodesign Regulation requires them to be effective, proportionate, and dissuasive, and they apply to more than just manufacturers. Distributors, importers, and online platforms that fail to meet their DPP obligations can also be held accountable.
There’s also a consumer-facing angle that’s easy to overlook: consumers have a right to claim compensation for damage caused by non-compliant products, and that claim can be directed at the manufacturer, or the importer or authorised representative if the manufacturer isn’t established in the EU. If none of those are EU-based, liability can shift to the fulfilment provider. That’s one more reason “we’ll deal with DPP later” is a riskier position for non-EU sellers than it might seem.
How to Prepare for DPP Registration Now
A few things are worth doing now, even if your product category’s obligation is still a couple of years out.
Start with the organisation-level enrolment rather than waiting until you have a specific product ready to register. Set up your EU Login, and arrange a qualified electronic seal or signature from a Qualified Trust Service Provider, which is the step most likely to cause delays. Check that the details on your certificate exactly match your company registration data. Use the testing environment to actually walk through the registration flow before it matters, so your team isn’t learning the system under deadline pressure. Map out which of your products fall under which delegated act or regulation, since the 2026-2029 timeline above isn’t uniform and getting the category wrong could mean you’re either scrambling late or investing effort too early. And if you’re a non-EU business, confirm now who will act as your economic operator for registration purposes, since this typically isn’t something a business outside the EU can complete entirely on its own.
How Euverify Can Help
Euverify works with manufacturers, importers, and ecommerce sellers navigating EU and UK compliance, including EU’s Digital Product Passport requirements. That includes helping you work out which delegated acts apply to your products, organising the documentation and traceability data a DPP will require, and supporting you through registration once your category’s obligation takes effect. If you’re not sure where your business currently stands against the DPP timeline, get in touch with us.
Frequently Asked Questions
Yes, for economic operators placing products covered by relevant EU legislation on the EU market. Registration in the Registry is a prerequisite for placing a covered product on the Single Market, though the requirement is being phased in by product category.
The DPP is the detailed record of a product’s information, hosted by the economic operator or a service provider. The Registry is a central EU database holding each product’s unique identifier and limited metadata, pointing to where the full passport is stored.
Both, as separate steps. Your organisation enrols first by signing or sealing a Commission-issued declaration with a qualified electronic seal or signature. The person who completes enrolment becomes the Administrator. Individual passports are then registered against that organisation using each product’s Unique Product Identifier, once your product group is available in the Registry.
18 February 2027, for certain categories of large batteries under the EU Battery Regulation. Other product categories follow on separate timelines set out in the ESPR working plan, running from 2026 through 2029.
Yes. As well as registering passports one at a time through an online form, you can upload an XML or JSON file containing up to 100 passports per submission, using templates provided in the Registry. The Registry is also designed to support API access for businesses that want to connect registration to their own systems.
Penalties are set by individual Member States and apply to manufacturers as well as other economic operators, including online platforms. Consumers also have a right to compensation for damage caused by non-compliant products, which can extend liability to importers, authorised representatives, or fulfilment providers.
You can enrol your organisation now. Registering product passports is being rolled out one product group at a time. Batteries are the first group available, but battery registrations can’t be completed until the Commission finalises that product group’s data model.
