What the EU DPP Registry Requirements Actually Cover
Regulation (EU) 2024/1781 (the Ecodesign for Sustainable Products Regulation, or ESPR) requires the European Commission to set up a central digital product passport registry. Article 13(1) of ESPR sets the deadline for the Commission: it must set up the registry by 19 July 2026. Understanding the EU DPP registry requirements means understanding what the registry does, what it does not do, and who carries legal responsibility for each part of the system.
The registry is not a database of product passport content. It stores, at a minimum, the unique identifiers assigned to products and, for products entering the customs procedure “release for free circulation,” the commodity code. The actual passport data sit elsewhere, held by the economic operator responsible under the relevant product legislation.
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The Commission operates the registry. Article 13(6) of ESPR states that the Commission, competent national authorities, and customs authorities have access to it for carrying out their duties under Union law. Access for verified economic operators and verified value chain actors is set by Implementing Regulation (EU) 2026/1778, as described below.
The Commission also adopted the implementing act that sets out how the registry works in practice: Implementing Regulation (EU) 2026/1778 of 16 July 2026, which entered into force on 6 August 2026. Articles 3 to 5 and 8 of that regulation cover the structure of the registry, user verification, registration rules, and how the unique registration identifier is communicated back to the registering operator.
What Gets Stored in the Registry
Article 13(1) of ESPR specifies that the registry stores, at a minimum, the unique identifiers, including the unique identifiers for batteries referred to in Article 77(3) of Regulation (EU) 2023/1542 (the Battery Regulation). For products entering the customs procedure “release for free circulation,” the commodity code is also stored.
The registry is not a public database. Access to the registry is limited by law. ESPR Article 13(6) gives access to the Commission, competent national authorities and customs authorities, and Implementing Regulation (EU) 2026/1778 grants access to verified economic operators for the purpose of registering passports (Article 4(3)) and only to verified value chain actors (Article 5(3)). The one part any user can search is the semantic repository of data definitions and structures, set out in Article 12(5) of the same implementing regulation. Tiered access to the content of the passport itself is governed by product-specific legislation, for example by ESPR delegated acts under Article 9(2)(f) of ESPR and, for batteries, by Article 77(2) and Annex XIII of Regulation (EU) 2023/1542.
The Battery Passport and the Registry: Two Separate Systems
Manufacturers of batteries often ask whether the registry replaces the battery passport. It does not. The two systems have different legal bases and different functions.
The battery passport is governed by Article 77 of Regulation (EU) 2023/1542. Under Article 78, point (c), of that regulation, the passport data are stored by the economic operator responsible under Article 77(4) or (7), or by operators authorised to act on its behalf; Article 77(4) allows written authorisation of another operator. For ESPR products more broadly, Article 10(4) of ESPR requires the operator placing the product on the market to make a back-up copy of the passport available through a digital product passport service provider.
The registry connects to the battery passport through Article 77(10) of Regulation (EU) 2023/1542, a provision added by Article 78 of ESPR. That provision requires the economic operator placing the battery on the market or putting it into service to upload the battery’s unique identifier into the registry. The registry records that identifier. The passport data themselves remain with the responsible operator or its authorised service provider.
See also the EU Central Registry for battery passports page.
Who Uploads Data to the Registry and When
Under Article 13(4) of ESPR, the economic operator placing the product on the market or putting it into service is responsible for uploading the required data to the registry. Once the upload is complete, Article 13(5) of ESPR requires the registry to automatically communicate a unique registration identifier back to that operator. The regulation is explicit that the registry’s communication of this identifier “shall not be deemed to be proof of compliance” with ESPR or other Union law. Receiving it does not mean your product has been approved or verified.
For batteries specifically, Article 77(10) of Regulation (EU) 2023/1542 (as added by ESPR Article 78) places the upload obligation on the economic operator placing the battery on the market or putting it into service. That operator must upload the unique identifier of the battery to the registry.
EU DPP Registry Requirements and Customs
The registry connects directly to customs procedures. Article 15(1) of ESPR requires that, for products covered by an ESPR delegated act, the person intending to place those products under the customs procedure “release for free circulation” must provide customs with the unique registration identifier once the registry is operational.
Customs authorities will verify that identifier and the commodity code against the registry. Under Article 15(2) and (3) of ESPR, this verification will happen electronically and automatically from the moment the interconnection between the registry and the EU Customs Single Window Certificates Exchange System (EU CSW-CERTEX) is operational. That interconnection must be in place within four years of the implementing act entering into force. Since Implementing Regulation (EU) 2026/1778 entered into force on 6 August 2026, the four-year window runs from that date, though the exact date the interconnection becomes operational will depend on when the technical link is established.
This means importers of products covered by ESPR delegated acts will need to obtain a valid unique registration identifier before customs clearance. Without it, release for free circulation will not be possible once the interconnection is live.
What the Registry Does Not Cover Yet
The registry covers products under ESPR delegated acts and, under Article 1(1) of Implementing Regulation (EU) 2026/1778, batteries, construction products, toys, and detergents and end-user surfactants. No ESPR delegated act setting passport requirements has yet been adopted for any product group. The Commission’s working plan COM(2025) 187 gives indicative adoption years for named product groups, but those are planning estimates, not confirmed dates. Under Article 4(4) of ESPR, a delegated act cannot require compliance earlier than 18 months after it enters into force, except in duly justified cases or in cases of partial repeal or amendment of delegated acts.
Batteries are a special case. The battery passport obligation under Regulation (EU) 2023/1542 has its own timeline set in that regulation, and the registry upload obligation for batteries flows from Article 77(10) of that regulation as amended by ESPR. The Commission was required to set up the registry by 19 July 2026 under Article 13(1) of ESPR, and the implementing regulation entered into force on 6 August 2026.
Practical Steps for Manufacturers
- Identify your product group. Check whether an ESPR delegated act has been adopted for your product. If not, monitor COM(2025) 187 for the indicative adoption year for your category, and track when the delegated act enters into force, since that starts the 18-month minimum period under Article 4(4) of ESPR, subject to the exceptions in that paragraph.
- Understand the upload obligation. Under Article 13(4) of ESPR, the operator placing the product on the market or putting it into service is responsible for uploading data to the registry. For batteries, Article 77(10) of Regulation (EU) 2023/1542 places the same obligation on that operator specifically for the unique identifier.
- Do not confuse the registry with the passport. The registry stores identifiers. The passport stores product data. Your obligation to maintain and make available passport data under Article 77(4) or (7) of Regulation (EU) 2023/1542, or Articles 9 to 11 of ESPR, is separate from the registry upload obligation.
- Prepare for customs. If you import products covered by an ESPR delegated act, you must provide the unique registration identifier to customs from the moment the registry is operational (ESPR Article 15(1)), and customs will verify it automatically once the EU CSW-CERTEX interconnection is live (Article 15(2)). Plan your registry registration process before that point.
- Verify access rights. The economic operator that registers passports must be a verified economic operator under Article 4(3) of Implementing Regulation (EU) 2026/1778. A third party that registers passports on its behalf must complete the verification process in Article 5 (Article 19(4)). Value chain actors who need access to the registry must be verified under Article 5(3) of the same regulation.
The Unique Registration Identifier Is Not a Compliance Certificate
Article 13(5) of ESPR is clear: the registry’s automatic communication of the unique registration identifier after upload “shall not be deemed to be proof of compliance” with ESPR or other Union law. The registry’s automatic checks do not replace market surveillance: verifying the substantive correctness of registered data remains a task for market surveillance authorities (recital 16 of Implementing Regulation (EU) 2026/1778). Receiving the identifier means your data have been recorded in the registry. It does not mean your product has passed any conformity assessment.
Compliance with the substantive requirements of ESPR, including the information requirements set in delegated acts under Article 9(2) of ESPR, and compliance with the battery passport content requirements in Annex XIII of Regulation (EU) 2023/1542, remain your responsibility as the economic operator.
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