The Digital Product Passport Registry Is Open: Do I Need to Register Too?
Audience: General management or compliance manager, manufacturing company, Europe
The short answer has two parts. Yes, the registry is open: since 20 July 2026, your company can officially register. No, you do not need to do so yet: no obligation currently applies to you, and even if you wanted to, you would not yet be able to register a product passport successfully. There was considerable confusion surrounding those days in July, so it is worth understanding what actually happened.
What the Digital Product Passport Registry Is, and What It Is Not
The European Digital Product Passport (DPP) Registry, established under Article 13 of the ESPR Regulation, serves a specific purpose. The most important thing to clarify is what it is not: it is not the repository that stores product passports.
It is an index.
Given a product identifier, the registry indicates where the relevant product data is located and routes requests to the parties entitled to access it, such as market surveillance authorities. The actual data remains with the economic operator that manages it, not within the registry itself. Think of it as a large switchboard or a search engine for identifiers: it does not store the content, it simply knows where that content resides.
What Actually Happened
This is where most misunderstandings originated, and the confusion disappears once three distinct dates are separated.
On 17 July 2026, the European Commission published the implementing regulation defining how the registry operates, meeting the legal deadline of 19 July set by the ESPR.
On 20 July 2026, the registry officially opened.
On 6 August 2026, that regulation entered into force.
These are three different events, and much of the confusion comes from treating them as one.
As a result, 19 July was not the day companies started uploading Digital Product Passports. It was simply the deadline by which the legal framework had to be in place, and the Commission met that requirement.
Nor is everything available from day one.
Today, company registration is operational, and it is far from a formality. An EU account is required. The system generates a declaration that must be sealed outside the platform using a qualified electronic seal issued in the company’s name. A qualified electronic signature belonging to an individual is sufficient only for sole proprietorships. The declaration must then be uploaded and verified. For smaller companies that do not already possess such a seal, this is a genuine hurdle.
What is not yet operational is the registration of actual product passports.
At present, the only product group available in the registry menu is batteries. The only granularity currently supported is the individual item level. However, the data dictionary for that product group has not yet been published, and without it, registration cannot be completed successfully by anyone. The list of verified service providers is also still missing, as are the automated interfaces required for data exchange.
There is also a phased approach to compliance obligations.
The first mandatory Digital Product Passports will apply to certain categories of batteries, including those used in electric vehicles and electric bicycles, starting on 18 February 2027. Member States have until the same period simply to appoint the national contact point responsible for distributing access rights to their authorities. For all other sectors, Digital Product Passports will be introduced through their respective delegated acts, and none of those product-specific rules have yet been adopted.
This is why, for the vast majority of companies, no compliance obligation has started yet.
So Why Should I Care About It Now?
For two reasons.
First, it is tangible proof that the roadmap established by the ESPR is progressing and doing so on schedule. The Digital Product Passport infrastructure is no longer a policy concept on paper. It now has a regulatory framework defining how it works, who is responsible, and when milestones are expected. It also has a live operational platform.
Second, it is useful to understand the architecture of the system your company will eventually have to interact with.
Understanding that the registry is an index, not a repository, changes how you approach data management. You will not be required to upload all your product information into a central European database. What enters the registry is primarily an identifier and a limited set of service-related data. The underlying product information remains under your control. Your task is to keep that data organized, accessible, and ready to be shared when required.
There is also a practical reason to begin looking into the system now.
Registering a company requires a qualified electronic seal issued to the legal entity itself, obtained from a trust service provider. The personal digital signature of a company director or legal representative is not sufficient. It is better to discover and address that requirement today than on the day compliance becomes mandatory.
Whether it makes sense to take action now or wait until the obligations for your sector come into force is a separate question. I address that issue in the dedicated Q&A on delegated acts.
The opening of the registry does not require you to take immediate action, but it sends a clear signal. The Digital Product Passport Registry has been open since July, its legal framework has been in force since August, and the system will continue to be completed over the coming months. Remember: it is an index, not a repository. Your task is not to deposit your data elsewhere, but to keep it under your control, clean, structured, and ready for use. Companies that already have their data in order today will not be scrambling when compliance obligations eventually arrive.
