EU DPP Registry · ESPR Article 13

The EU registry: what's live, what's pending.

Article 13 of the Ecodesign for Sustainable Products Regulation (EU) 2024/1781 required the European Commission to set up a central Digital Product Passport registry by 19 July 2026. It went live on 20 July. It is one of the most misunderstood pieces of the DPP architecture — and one of the most misrepresented in vendor marketing. Here is what the registry actually is, what it is not, and exactly where it stands.

Last updated: · status statements are accurate as of this date

The design

An index of identifiers — not a passport database

The EU Digital Product Passport registry is an index: it stores the unique identifiers of products, operators and facilities, together with data-carrier references, and resolves them to passports hosted elsewhere. It does not host passport data itself.

That design decision — written into ESPR's decentralised architecture — is the whole point. Passport data stays on infrastructure chosen by the economic operator (or their service provider), under their control; the registry maps a Unique Product Identifier to the exact URI where the passport lives. Market-surveillance authorities query the registry to find a passport; they read the passport from wherever it is hosted.

Two practical consequences follow. First, hosting and persistence remain the operator's obligation — the registry will not preserve your data for you (that duty is shaped by EN 18221; see the standards guide). Second, the identifier scheme matters more than ever: what you register must be exactly what your QR codes resolve (EN 18219, GS1 Digital Link).

Where it stands

Status as of July 2026

The registry went live in production on 20 July 2026, and the implementing regulation that governs it — Commission Implementing Regulation (EU) 2026/1778 — was adopted on 16 July and published in the Official Journal on 17 July. Enrolment and registration are open to economic operators today through a web interface, with single-record entry and batch submission of up to 100 records as JSON or XML. What does not exist is a documented operator-facing machine API: the Commission has published a User Guide for Economic Operators, not an integration specification.

What that means in plain terms: the gate moved from availability to identity, and then to semantics. No organisation can register anything until it is verified — EU Login, plus a declaration sealed by the Commission and counter-sealed offline with a qualified electronic seal from a Qualified Trust Service Provider (a qualified electronic signature, where the operator is a sole trader). And for the first product group, verification is not enough: the Commission states that battery registrations cannot currently succeed, because the semantic catalogue for batteries has not been defined. Registration duties bind when product-specific rules apply — for the first products in scope (batteries, from 18 February 2027; see the battery passport guide), registration happens before placing the product on the market.

A battery passport cannot be successfully registered in the EU registry today — the Commission's semantic catalogue for batteries does not exist yet, and the registry says so in its own user guide. If a provider claims live battery registry integration, ask them to show you a successful registration and the identifier it returned.

— The one due-diligence question that sorts the market (status as of July 2026)
Honest positioning

What "registry-ready" means at OpenDPP

OpenDPP is registry-ready, not registry-connected — and we say so deliberately. The registry is live, but battery DPPs cannot yet be registered in it and no operator-facing machine API is documented. What exists today is everything the registry indexes — plus a pointer projection we have proven, end to end, against the CIRPASS-2 reference implementation of that index: it registers, returns a cryptographically verifiable proof of registration, and is discoverable.

Concretely: every OpenDPP passport already carries a standards-shaped unique identifier (GS1 GTIN/GRAI product keys, GLN facility identifiers), is resolvable at a stable GS1 Digital Link URI, and stays resolvable through the retention window. We go a step beyond shape: OpenDPP projects each passport into the exact Article 13 pointer record — product identifier, responsible-operator id, facility GLNs, primary and backup resolution URLs, commodity code and granularity — and validates that record against the CIRPASS-2 mock EU registry's own schema. In our open interop harness we go further: that pointer is registered against the running CIRPASS-2 reference registry — which returns a cryptographically verifiable Proof-of-Registration — and its discovery keys resolve in the reference data-extractor; the schemas, the field mapping and a reproducible validator are published in our open interop kit, so anyone can check it without our source. CIRPASS-2 is an EU-funded reference project, not the Commission's production registry, and it grants no certification. The Commission's production registry is now live, though battery DPPs cannot yet be successfully registered there — the Batteries semantic catalogue is still pending. The registry also caps a registered Unique Product Identifier at 50 resolvable characters: every OpenDPP battery unit already meets it with a compact resolvable link, so when battery registration opens, registering is a submission step, not a re-architecture. That is the practical meaning of readiness: your identifiers and links are already in the shape the registry indexes.

Primary sources

Where these facts come from

Legal basis: Regulation (EU) 2024/1781, Article 13. Implementation status: the Commission's ESPR implementation hub and the CIRPASS-2 project (consultation response, 27 May 2026). Related reading: the EN 182xx standards guide and the ESPR timeline.

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Key takeaways

Article 13 of ESPR (EU) 2024/1781 required the European Commission to set up a central Digital Product Passport registry by 19 July 2026; it went live in production on 20 July 2026. The registry is an index, not a data host: it stores unique identifiers and data-carrier references and resolves them to passports hosted by economic operators or their providers. Commission Implementing Regulation (EU) 2026/1778, adopted 16 July 2026, governs it. Enrolment requires EU Login plus a Commission-sealed declaration counter-sealed with a qualified electronic seal from a Qualified Trust Service Provider. Registration is open through a web interface with single and batch submission, but battery DPP registrations cannot yet succeed because the semantic catalogue for batteries has not been defined, and no operator-facing machine API is documented.

The EU DPP Registry: live since 20 July 2026, and what still blocks registration · Last reviewed