Digital product passport: the EU registry is live

Author Hugues Orgitello Last updated 22 August 2026 ~6 min read

News · Regulatory evolution

Article 13(1) of Regulation (EU) 2024/1781, the ESPR, required the Commission to set up "by 19 July 2026" a digital registry storing at least the unique identifiers. The Commission announced on 20 July 2026 that the registry was live, together with a testing environment. Three days earlier the implementing regulation setting its operating rules had been published; five days earlier, six harmonised DPP standards were cited in the Official Journal. The digital product passport is no longer a promise deferred to future delegated acts: it is now operational infrastructure.

In short:

The DPP registry was announced live on 20 July 2026; the Article 13(1) statutory deadline was 19 July 2026.
Implementing Regulation (EU) 2026/1778 sets the registry architecture, operator identity verification and the unique registration identifier.
Implementing Decision (EU) 2026/1736 cited six harmonised DPP standards in the OJEU, opening the Article 41(2) presumption of conformity.
The first genuine registration deadline is 18 February 2027, for LMT, industrial (above 2 kWh) and electric vehicle batteries.
19 July 2026 is also the date the ban on destroying unsold clothing and footwear became applicable (Article 25(1)).

Four dates in one week

Date	Act	Effect
15 July 2026	Implementing Decision (EU) 2026/1736 of 14 July 2026	Six harmonised DPP standards cited in the OJEU
17 July 2026	Implementing Regulation (EU) 2026/1778 of 16 July 2026	Registry operating rules, in force 6 August 2026
19 July 2026	ESPR, Articles 13(1) and 25(1)	Registry deadline; ban on destroying unsold apparel and footwear
20 July 2026	Commission announcement	DPP registry and testing environment open

What the registry stores, and what it does not

The registry does not host passports. Article 11, point (c), of the ESPR provides that the DPP is stored by the economic operator responsible for creating it or by a DPP service provider, and Article 10(4) requires that operator to make a back-up copy available through such a provider. The registry itself stores at least the unique identifiers, the commodity code for products intended to be released for free circulation, and the unique identifiers of the batteries referred to in Article 77(3) of Regulation (EU) 2023/1542. Article 3 of Implementing Regulation (EU) 2026/1778 describes it as nine components, among them a secure web interface, an API, a verification platform, a semantic repository and the list of verified DPP service providers.

One point for quality teams: Article 13(5) states that communication of the unique registration identifier "shall not be deemed to be proof of compliance" with the Regulation or other Union law. Registration is an administrative act, not an assessment. Article 15 separately requires that identifier to be supplied to customs for products covered by an Article 4 delegated act, once the registry is operational.

Becoming a verified economic operator

The implementing regulation inserts an identity step ahead of any registration. Article 4 restricts registration to "verified economic operators": a qualified electronic signature or a high-assurance electronic identification means for a natural person acting as a sole trader, a qualified electronic seal supported by a qualified certificate for a legal person, all under Regulation (EU) No 910/2014. Verified status lapses when the electronic identification means expires and in any event three years after verification.

Registration itself (Article 8) runs through the secure interface or the API. The system checks the semantic conformity of the data, its coherence, the granularity level (model, batch or item), the validity of the commodity code and the link to the back-up copy, then generates a unique and persistent registration identifier. Where several Union instruments cover the same product at different granularity levels, the most granular one applies.

Article 9 creates a document worth knowing about in B2B dealings: a "proof of registration", a sealed electronic document carrying the unique product identifier, the identity of the verified operator, a time stamp for the latest registered version and a hash of it, available for 90 calendar days. Each Member State must also appoint a designated national administrator by 18 February 2027 (Article 7(1)).

Six harmonised standards, and what they cover

Reference	Subject
EN 18216:2026	Data exchange protocols
EN 18219:2026	Unique identifiers
EN 18220:2026	Data carriers
EN 18221:2026	Data storage, archiving and persistence
EN 18222:2026	APIs for passport lifecycle management and searchability
EN 18223:2026	System interoperability

Recital 5 of the decision states that they satisfy the requirements of Articles 10 and 11 of the ESPR. The legal effect is the one set out in Article 41(2): a passport conforming to those standards, or parts of them, is presumed to conform to Articles 10 and 11 "to the extent that those requirements are covered". The presumption is therefore partial by construction, exactly as for the standards cited under the RED.

A separate battery passport, a shared registry

The battery passport is not an ESPR DPP. It lives in Article 77 of Regulation (EU) 2023/1542: 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 must have an electronic record, with its own content and its own three access tiers. Portable batteries are out of scope: a smartphone battery has no battery passport, while an e-bike battery, being an LMT battery, does.

The bridge is written into the ESPR. Article 78 adds a paragraph 10 to Article 77 of the Batteries Regulation obliging the operator to upload the unique identifier into the Article 13(1) registry. That is why the registry's first operational deadline is a battery deadline. Article 2 of Implementing Regulation (EU) 2026/1778 confirms it: "digital product passport includes the battery passport".

What 19 July 2026 is not

No ESPR Article 4 delegated act, textiles or otherwise, has been adopted to date. The only ESPR delegated act in force is Delegated Regulation (EU) 2026/296 of 9 February 2026, published on 22 April 2026, which sets ten derogations, (a) to (j), from the destruction ban and applies from 19 July 2026; the supporting documentation must be kept for five years. The ban in Article 25(1) covers only Annex VII: apparel and clothing accessories (CN 4203, chapters 61 and 62, CN 6504 and 6505) and footwear (CN 6401 to 6405). It does not apply to micro and small enterprises, and applies to medium-sized enterprises from 19 July 2030.

A correction to a figure that circulates widely, including in our own guides: Article 5(1) enumerates sixteen product aspects, (a) to (p), not twelve. The possibility of remanufacturing (l), recyclability (m) and the possibility of the recovery of materials (n) are three distinct points.

Where electronics sit

The first ESPR working plan, Communication COM(2025) 187 final of 16 April 2025, runs 2025 to 2030 with a mid-term review in 2028. ICT products and electronics are not a stand-alone product group in it: the document states that they "are not listed above" and will be handled through the two horizontal measures and through the energy-related products work.

Measure	Indicative year
Repairability, including scoring	2027
Recycled content and recyclability of EEE	2029
Displays	2027
EV chargers	2028
Mobile phones and tablets	end 2030
Standby and off mode consumption	end 2030

The horizontal repairability measure is the most immediate timing risk: its scope "could include products such as consumer electronics and small household appliances". One further date belongs in the compliance schedule: Article 79(1)(a)(i) keeps parts of Directive 2009/125/EC applicable "until 31 December 2026" for a list of products that includes computers, servers and data storage products, external power supplies, photovoltaic panels and imaging equipment.