The EU registry for Digital Product Passports: who has to register, and when

What is the EU DPP registry?

The EU DPP registry is the central verification and search layer for Digital Product Passports in the single market. It is operated by the European Commission; the legal basis is set out in Articles 12 and 13 of the Ecodesign Regulation (EU) 2024/1781.

What matters is what the registry is not: it is not a database in which the product passports are held. Only the unique identifier of each product passport and a small amount of metadata are recorded - for example on the responsible economic operator and the product group. The passport content itself remains stored decentrally at the company or its service provider and is located via the identifier.

This architecture resolves two opposing requirements: market surveillance and customs need a reliable entry point in order to check whether a passport exists for a product at all and who stands behind it. Companies, in turn, have good reasons not to push material compositions, supplier details and CO₂ figures into a central EU database. The registry combines both: centrally findable, decentrally stored.

What a product passport actually contains is explained in the comprehensive DPP guide.

Since when has the registry been in operation?

The registry has been live since 20 July 2026. The Commission provided it together with a test environment in which companies and software providers can trial their integration - details in the announcement from the European Commission.

Alongside it, technical documentation, implementation guidelines, webinars and a helpdesk are available. For most companies this is the most important part: the integration can be tested long before it becomes mandatory.

An important point of context: “in operation” does not mean “mandatory for everyone from now on”. The registry is the infrastructure; the registration obligation arises only through the respective product regulation. The first of these takes effect on 18 February 2027.

Who has to register - and what exactly?

The party subject to registration is the economic operator who places the product on the EU single market. That is as a rule the manufacturer - and the manufacturer is whoever’s brand appears on the product. For goods from third countries the importer moves into this role; pure distributors who resell third-party branded goods do not register themselves. The distinction is set out in the guide Who is responsible for the DPP?

For each product passport, the following has to be registered:

• the unique identifier of the passport, through which it becomes findable,
• a set of metadata, including on the economic operator and the product group.

What does not have to be transmitted is the passport content. If you fear that registration means handing bills of materials, supplier lists or emission values to an EU database: that is not the mechanism. This data stays where the passport is hosted.

At what level registration takes place - per item, batch or model - does not follow from the registry but from the regulation for the respective product group.

Registration via interface or API

The Commission offers two routes - a secured web interface and an API.

The web interface is suitable for manageable volumes: few products, few changes, no system integration needed. It also makes sense as a control route, to see which entries are held under your own economic operator.

The API is the route for everyone else. As soon as a range consists of hundreds of articles with variants, or batches change continuously, manual entry is not a viable process. Identifiers and metadata are reported system-to-system via the interface - ideally automatically, as soon as a new passport is published.

For small and medium-sized brands this has one pleasant consequence: as a rule you will never touch this API yourself. The integration is handled by the DPP software in use; responsibility for its accuracy nevertheless remains yours. That is exactly why the question “Do you integrate with the EU registry, and from when?” belongs in every selection conversation - the DPP software comparison lists it as a criterion in its own right.

Proof of registration in B2B business

One detail that quickly becomes relevant in day-to-day work: economic operators can request a secure electronic document that evidences the registration.

The proof has two audiences. Towards market surveillance it demonstrates that a registered passport exists for a product. In B2B business it becomes the document that buyers ask for out of self-interest: distributors have to verify before offering a product that a required product passport is present and accessible - a machine-verifiable proof is more efficient for this than a screenshot of a product page.

A realistic expectation: the proof will end up where CE declarations of conformity and test reports sit today - in supplier onboarding, in listing documents and in tenders.

Deadlines: what applies from when?

Two points on how to read this. First: only the battery row is a genuine date. 18 February 2027 applies to large batteries - EV batteries, industrial batteries above 2 kWh and LMT batteries, which includes e-bike and e-scooter batteries. Portable batteries are not covered by this key date. Details: DPP for batteries & e-bikes.

Second: for the ESPR groups the “key date” column deliberately says “open” - the registry has made provision for these groups, but a slot in the registry is not a legal act. Expected planning years can be found in the deadline overview; the ESPR deadline checker will place your own exposure in a few minutes.

Registry ≠ conformity

This is the point at which the first misunderstandings will surface in 2027, so to put it plainly: an entry in the EU registry does not make a product conformant.

The registry stores the pointer, not the content. What a product passport has to contain - mandatory fields, data formats, access rights, retention obligations - follows exclusively from the delegated act for the respective product group, or from the relevant sector regulation. A cleanly registered identifier that points to an incomplete passport is therefore exactly that: a cleanly registered infringement.

For the ESPR product groups there is an additional factor as of September 2026: for textiles, tires, furniture and mattresses no delegated act has yet been adopted. So there is still no legally binding list of mandatory fields to validate against - and therefore no serious assurance that a passport created today will later be complete. How the interplay between the regulation and delegated acts works is explained in the guide ESPR explained.

It also remains open how the member states will enforce and sanction the obligation nationally. The ESPR leaves the sanctions framework to the member states; reliable statements on the level of fines cannot be derived from it for 2026.

This guide summarises the publicly documented status of the EU DPP registry as at 3 September 2026 and does not replace legal advice in individual cases.

What companies should do now

1. Clarify your role and your exposure. For a given article, are you the manufacturer, the importer or a pure distributor? The question arises per product, not across the board for the company - and only the first two roles register.
2. Plan the battery deadline backwards. If you have to deliver by 18 February 2027, you will obtain cell chemistry, capacity, carbon footprint and recycled content from the supply chain, not from in-house. That is the long part, not the registration.
3. Pin down the registration route with your software provider. Ask specifically: interface or API, who reports the identifiers, from when is the integration in place, has it been trialled in the test environment? A roadmap promise is not an integration.
4. Build the data base independently of the legal act. Material, origin, certificates and repair information per article will be needed in every conceivable version of a delegated act. Anyone who starts only after it is published loses the transition period - for textile brands, the entry point is described on the page DPP for textile companies.

The registry itself is ultimately the simplest building block: an identifier, a few items of metadata, an automated call. What is laborious is everything before it - collecting and validating the data per article and keeping the published passport up to date over the product lifetime. That is exactly what SolveDPP’s DPP software is built for: import of products and variants from Shopify, validation before publication, hosted passport pages including QR code - and an integration with the EU registry that you do not have to develop yourself.