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The DPP Registry Is Live. Almost Nothing Is Due Yet
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11 min read
Last updated Sep 25, 2026
The European Commission opened the Digital Product Passport registry on 20 July 2026, and a wave of guides turned that into an instruction to act now. It is not one. No product covered by the Ecodesign Regulation needs a passport today, because the delegated acts that would require one do not exist yet. Exactly one deadline is real, it lands on 18 February 2027, and it is considerably narrower than almost everything written about it.
The EU Digital Product Passport registry opened on the twentieth of July twenty twenty-six. It does not make passports mandatory. A product needs a digital product passport only when a delegated act under the Ecodesign Regulation, or another EU law such as the Battery Regulation, requires one. The first such requirement applies from the eighteenth of February twenty twenty-seven, and it covers only larger battery types.
What actually happened in July 2026?
The Commission built the plumbing and said so plainly. Its announcement opens: "Today, the European Commission launches the Digital Product Passport Registry together with a testing environment, marking an important milestone in making the Digital Product Passport (DPP) a practical reality for businesses placing products on the EU market." A milestone in making it practical is not the same as making it compulsory, and the difference is the whole of this article.
The architecture matters because it shapes what you will eventually have to do. Product data stays with you: "While product data is stored in a decentralised manner, economic operators must register each Digital Product Passport in the Registry, which provides the secure infrastructure needed to register unique product identifiers and associated metadata." So the registry holds identifiers and metadata, not your bill of materials. Registration runs "through either a secure user interface or an application programming interface (API)", and you can request "proof of registration in the form of a secure electronic document" to show to trading partners.
| Date | What it is | Binding on a seller? |
|---|---|---|
| 19 July 2026 | ESPR Article 13(1) deadline for the Commission to set up the registry | No, an obligation on the Commission |
| 20 July 2026 | Registry and testing environment go live | No, infrastructure |
| 6 August 2026 | Implementing Regulation (EU) 2026/1778 takes effect | No, it governs the registry |
| 18 February 2027 | Battery passport for LMT, over 2 kWh industrial and EV batteries | Yes, for those battery types |
| 18 February 2027 | QR code on all batteries, including portable | Yes, for anyone selling batteries |
| Not yet set | First ESPR delegated act, then 18 months minimum before it applies | Not yet |
The Commission missed its own deadline by one day
Article 13(1) of the Ecodesign Regulation says: "By 19 July 2026, the Commission shall set up a digital registry (the 'registry') which stores in a secure manner at least the unique identifiers." The registry opened on 20 July 2026, one day late. That is worth knowing not as trivia but as a signal: a schedule of this kind slipping by a single day is, in practice, a schedule being kept, so the 2027 battery date deserves to be treated as real rather than as another deadline that will drift. One line of that same article is worth a battery seller's attention: the registry "shall store the unique identifiers for batteries as referred to in Article 77(3) of Regulation (EU) 2023/1542". The registry you can ignore this year is where your battery identifier lands in 2027.
Does the registry switch on a customs check?
The registry arms one, but it currently points at an empty set. Article 15 of the Ecodesign Regulation is titled Customs controls relating to the digital product passport, and it reads: "Any person intending to place a product covered by a delegated act adopted pursuant to Article 4 under the customs procedure 'release for free circulation' shall provide or make available to customs authorities the unique registration identifier of that product... The first subparagraph of this paragraph shall apply from the moment the registry is operational."
One clause carries the whole article: "a product covered by a delegated act adopted pursuant to Article 4". The duty attaches to a product covered by a delegated act adopted pursuant to Article 4, and no such delegated act has been adopted. The registry being operational satisfies one condition of a rule whose other condition is still unmet, so nothing is owed at the border today. There is also a second switch further down: customs may release goods only after verifying the identifier against the registry, and that verification "shall take place electronically and automatically via the interconnection" and "shall apply from the moment that interconnection is operational".
Three conditions, and the first one is missing
Anyone writing that the registry is live, so customs will now check your products, has compressed three separate conditions into one headline. The obligation needs a delegated act to exist; the seller-side duty turns on with the registry; the automated customs verification turns on with the interconnection. Three conditions, and the delegated act does not exist, which settles it on its own. Plan for the sequence, not for the headline, and expect the first products to feel it to be those named in the first delegated act.
Which products have a real date?
Batteries, and not in the way most coverage says. The Commission's own announcement names the date and hedges the scope carefully: "The current testing phase will help ensure a smooth rollout ahead of the first implementation deadline on 18 February 2027 for certain types of large batteries." That hedge, certain types of large batteries, is doing real work, and the Battery Regulation says exactly which.
Article 77(1) of the Battery Regulation is precise: "From 18 February 2027 each LMT battery, each industrial battery with a capacity greater than 2 kWh and each electric vehicle battery placed on the market or put into service shall have an electronic record ('battery passport')." LMT means light means of transport, so e-bikes and scooters. Portable batteries are not in that list. If you sell AA cells, power banks or a toy with a battery in it, the passport requirement does not reach you.
But a second rule on the same date does reach you
Article 13(6) of the same regulation: "From 18 February 2027, all batteries shall be marked with a QR code as described in Part C of Annex VI." For the three passport types the QR code leads to the passport. For everything else it must lead to the labelling information, "the declaration of conformity referred to in Article 18, the report referred to in Article 52(3) and the information regarding the prevention and management of waste batteries". So the honest summary is not "batteries need a passport". It is: three battery types need a passport, and every battery needs a QR code, on the same day.
What about textiles, furniture and everything else?
Textiles, furniture and the rest sit on a plan rather than a deadline. The Commission adopted its Ecodesign and Energy Labelling Working Plan 2025-2030 on 16 April 2025, naming textiles and apparel, furniture, mattresses, tyres and metals as the priority groups, with iron and steel indicatively first. Those are planning dates for adopting a delegated act, and adoption is not application.
The gap between the two is written into the law. Article 4(4) of the Ecodesign Regulation: "The date of application of a delegated act shall not be earlier than 18 months from its entry into force, except in duly justified cases." That single sentence is the source of the eighteen months figure that circulates without a citation, and it means a delegated act adopted in 2027 generally bites in 2029. Anyone selling you urgency on textiles for next spring is selling you a planning date plus a misunderstanding.
- Iron and steel, indicatively adopted 2026, so applying no earlier than mid-2028 on the statutory minimum.
- Textiles and apparel, tyres, aluminium, indicatively 2027, applying 2029 or later.
- Furniture, indicatively 2028.
- Mattresses, indicatively 2029.
- Batteries, construction products, toys, detergents and surfactants sit outside this sequence entirely, because their passport duties come from their own regulations rather than from the Ecodesign Regulation.
So what is worth doing in 2026?
Collect the data, and let the deadlines come to you. The registry stores identifiers, which means the work that will eventually be demanded of you is upstream of it: knowing, per product, who manufactured it, in which facility, to which model or batch, and being able to hand that over in a machine-readable shape. Sellers who already hold that for GPSR or packaging registration are most of the way there.
The shape is not a mystery either, because the standards are published. The Commission notes that "eight harmonised standards underpinning the interoperability of the DPP system have been developed in close cooperation with the CEN-CENELEC" and that six "covering unique identifiers, interoperability, data carriers, APIs, data exchange protocols and data storage, are already available". There is also "a free semantic repository providing machine-readable data models, definitions and vocabulary across product groups through documented APIs", which is an unusually concrete thing for a regulator to ship before the rules land.
The passport is a carrier on the product, not a page on your website
Article 10 sets out what a passport has to be, and two of its requirements have physical consequences for packaging design. It "shall be connected through a data carrier to a persistent unique product identifier", and "the data carrier shall be physically present on the product, its packaging or on documentation accompanying the product". Persistent means it cannot be a link you rotate. The data must also be, "as appropriate, machine-readable, structured, searchable, and transferable through an open interoperable data exchange network without vender lock-in" (the typo is in the Official Journal), which is a high bar for a PDF on your own domain to clear. If you are redesigning packaging in 2027 anyway, that is the cheap moment to leave room for a carrier.
How to get ready without over-investing
- Sort your catalogue into the three buckets - Batteries and battery-containing products, ESPR priority groups such as textiles and furniture, and everything else. The first bucket has a 2027 date, the second has planning dates, and the third has nothing on the horizon. Most catalogues are mostly the third bucket, and knowing that is worth more than a compliance project.
- Work out whether any battery you sell needs a passport or only a QR code - Passport applies to LMT batteries, industrial batteries above 2 kWh and EV batteries. Everything else, including portable cells and batteries built into products, needs the QR code and the information behind it. Ask your supplier which of the two applies, in writing, and treat a vague answer as a no.
- Ask suppliers for identifiers now, not data later - The registry stores unique product identifiers, and where relevant operator and facility identifiers. Those come from your manufacturer and they take time to obtain. Requesting them in your next purchase order costs nothing and removes the item that has the longest lead time.
- Use the testing environment before you need it - The Commission shipped a testing environment alongside the registry, plus technical documentation and a helpdesk. If you have any in-house systems, having one person register one test product through the API tells you more about the eventual effort than any consultancy estimate.
- Do not buy a passport platform yet - No ESPR product requires a passport, the standards have only just been published, and the semantic repository is free. A subscription bought in 2026 to satisfy a rule that applies in 2029 is three years of fees for nothing. Revisit when the first delegated act naming one of your product groups is adopted.
- Put one recurring check in the calendar - The trigger to watch is the adoption of a delegated act covering a group you sell, because that starts the minimum eighteen-month clock and switches on the customs scope. Checking the Ecodesign working plan twice a year is enough, and it beats reacting to a headline.
The question that tells you whether this is urgent
Does anything you sell contain a battery? If yes, you have a February 2027 date, and the only thing left to establish is whether it is the QR code rule or the passport rule. If no, and you are not selling textiles, furniture, tyres or steel, then the Digital Product Passport is a 2029 problem for you, and the correct amount of work this year is collecting identifiers from suppliers you are already ordering from. That is the whole triage. It takes ten minutes and it is the difference between a calm 2027 and a panic.
Recent EU product law keeps the same shape: an obligation that lands on the marketplace before it lands on the rules, and a date that is real for one narrow group long before it is real for everyone. Our guide to the EU packaging rules under the PPWR covers the same shape for packaging registration, and the GPSR compliance guide covers the responsible-person requirement that most of this data collection also serves. If your catalogue crosses a border into the United States as well, the changes to US import rules are the other half of the compliance year.
Do I need a Digital Product Passport right now?
Almost certainly not. No ESPR delegated act has been adopted, so no product covered by the Ecodesign Regulation requires a passport. The first requirement anywhere is 18 February 2027 for LMT, over 2 kWh industrial and EV batteries.
What changed when the registry went live?
Infrastructure, not obligations. The Commission opened the registry and a testing environment on 20 July 2026, with registration by user interface or API and optional proof of registration for B2B use.
Will customs check my products against the registry?
Eventually, and only for products covered by a delegated act. Article 15 also makes the automated verification depend on an interconnection being operational, so two further conditions have to be met before it affects a shipment.
I sell power banks. Am I in scope in February 2027?
For the QR code, yes. For the passport, no. Article 13(6) requires a QR code on all batteries from that date, while the passport in Article 77 is limited to LMT, over 2 kWh industrial and EV batteries.
When do textiles actually need a passport?
Not before a delegated act is adopted, which the working plan indicates for 2027, and then not earlier than 18 months after it enters into force. That points at 2029 rather than next year.
Does Amazon collect DPP data from sellers?
Amazon has published no DPP attribute set, and nothing in the current sources says how it will collect one. Expect it to appear the way GPSR and packaging registration did, as a compliance field with a deadline attached, once a delegated act names a product group.
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