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Regulation

The EU DPP Registry: What the Commission Actually Published, and What Does Not Work Yet

By Pierre-Nicolas Hurstel · CEO & Co-Founder
8 min

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The registry is open. Registration is not.

The European registry for product passports has been live since 20 July 2026, at registry.product-passport.ec.europa.eu. The Commission describes it as the indexing service for all Digital Product Passports of products placed on the EU market.

On 24 August 2026, DG GROW published version 1.02 of the user guide for economic operators. It contains a callout worth reading before you plan anything:

Successful registration of DPPs for batteries is not currently available, as the semantic catalogue for this product group has not yet been defined. Currently, it is not possible to successfully register DPPs.

In other words: the infrastructure is standing, the journey is documented, the test environment is open — but the final step, the one that produces a valid registration, is still waiting on the battery semantic catalogue. That was the state of the guide on 24 August 2026; it is exactly the kind of line that disappears without notice, so check the current version before drawing conclusions from it.

This does not mean there is nothing to do. It means what there is to do today is not registration.

What the registry stores — and what it does not

The guide draws an explicit line between two objects, and that line is the whole architecture of the scheme.

Registration RecordDPP Data
What it isAn EU-level record referencing a passportThe full data structure of the passport
ContentIdentifiers, registration metadata, semantic metadata, access rulesThe attributes required by the product group schema
Where it livesThe Commission's central databaseThe economic operator's or its service provider's database
Who controls itThe Commission / public infrastructureThe economic operator, entirely

The registry "does not store the full DPP data", the Commission writes. It records the subset needed to identify the passport and reach it. Its stated purpose is an authoritative index for compliance checks, searches by authorities and cross-border enforcement — customs before release for free circulation, market surveillance afterwards.

The identifier mechanics come down to two acronyms. You supply the UPI (Unique Product Identifier): mandatory, in a URL format compliant with JTC 24 standards, 2,000 characters maximum, and it must resolve to wherever you host the data. The registry returns a URI (Unique Registration Identifier), the identifier of the central record, which binds it to your UPI.

One practical point that rarely gets mentioned: the guide states no subscription fee is expected — deliberately cautious wording, not yet a guarantee that it is free. The cost sits elsewhere anyway.

Enrolment is the real work

Under Regulation (EU) 2024/1781, only verified economic operators may register and manage DPPs. Verification is not a checkbox, and it is the piece to start now.

The documented journey:

  • An EU Login account, the central authentication service of the European institutions, with multi-factor authentication. If you want the registry access separate from an existing account, create a dedicated one.
  • Organisation information: the legal (registered) name — not a trading name — the legal address, and the country of registration.
  • An entity identifier, chosen from NTR (national trade register, explicitly preferred), LEI (ISO 17442), VAT number, eID, or a local definition prefixed by the country code.
  • Compliance contacts, which competent authorities may use to reach you about your registrations.
  • The legal representative, then a PDF declaration generated by the registry, to be electronically signed or sealed, uploaded and submitted.

That last step is what drives the calendar. A legal person seals with a qualified electronic seal (QSeal); a natural person signs with a qualified electronic signature (QES). Both sit under the eIDAS Regulation (EU) 910/2014 and are obtained from a qualified trust service provider (QTSP).

Here is the trap: the identifier you enter in the form must match the corresponding certificate attribute exactly — the guide specifies it is not a partial identifier, and points you to your QTSP if in doubt. A qualified seal is not something you buy in an afternoon, and a one-character mismatch between certificate and form gets the application rejected.

Once the organisation is verified, the person who applied becomes its administrator in the registry.

Registering a DPP: two methods, three granularities

When registration does open, two routes are provided.

The online form handles one passport at a time: UPI mandatory, model identifier and batch identifier optional. File submission handles a batch, in XML or JSON, with a downloadable template for each format and a ceiling of 100 DPPs per submission. Either way the request gets a correlation ID and an estimated validation time, tracked from an activity dashboard.

Granularity is chosen between Model, Batch and Item — the design, the production run, the individual unit. For batteries only the item level is available and pre-selected, as that is the agreed level for this product group. Batteries are also the first product group for which registration will open, with the rest following progressively in line with ecodesign requirements under the ESPR working plan.

The test environment already exists

This is the immediately usable part. The sandbox is open at registry.acc.product-passport.ec.europa.eu and covers both enrolment and registration. Three points from the guide that save surprises:

  • You need a different EU Login from the production one.
  • Nothing migrates to production, and objects created there may be removed by a data cleaning routine.
  • Verification is the same as in production: to create an organisation in test, you need valid organisation data and the required signatures or seals.

That last point is counter-intuitive and important: the sandbox does not exempt you from the qualified seal. You cannot rehearse the full journey without having already started the QTSP process.

What to do now

Three pieces of work, in this order.

Start procuring the qualified seal. It is the only item whose lead time is not yours to control, and it blocks everything else. While you are at it, check which identifier appears in the certificate — NTR, LEI or VAT — since that is the one you will have to enter verbatim.

Enrol in test, then in production. The journey is documented and open. Nothing stops you from arriving verified on the day registration opens, rather than discovering then that being recognised as an operator takes six weeks.

Make your UPIs resolvable. The registry does not host your data: it indexes a URL that has to answer, over time, and for which you remain responsible in both availability and accuracy throughout the passport's lifecycle. That is an infrastructure requirement, not a documentation one, and it is not fixed the night before.

The rest — the semantic catalogue, the per-product-group schemas — depends on the Commission's timetable. What is in your hands is verified identity and identifier resolution. Both are available today.

Sources

Every reference in this article comes from the European Commission and the Official Journal of the Union:

The Commission's DPP helpdesk answers at EC-HELPDESK-DPP@ec.europa.eu and +32 2 296 04 31, 08:00–20:00 CET.

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