The EU passport registry, and who must upload to it

The European Union digital product passport registry is a database that the European Commission runs. The company that places a product on the European market must upload to it. No company must upload yet, because no product rule applies. The registry stores at least the unique identifiers of covered products.

Two mistakes cost money here. The first is to pay for a registry upload for a product that no rule covers. The second is to treat a registration identifier as a certificate of compliance. It is not one, and the law says so.

The registry is operational, and a database is not a law

The registry comes from Article 13 of the Ecodesign for Sustainable Products Regulation (ESPR). Article 13(1) reads:

By 19 July 2026, the Commission shall set up a digital registry (the 'registry') which stores in a secure manner at least the unique identifiers.

The registry opened in July 2026. Two dates appear in published material, and both of them are correct. The Commission also cited six passport standards in the same month. See why passports are in the news now.

The Commission news item of the launch day says: "Today, the European Commission launches the Digital Product Passport Registry together with a testing environment."

Read the Commission announcement. This site calls the registry operational. It never calls the registry in force, because a law enters into force and a database opens.

Two addresses are on record.

No company must upload yet, because no product rule applies

An open registry does not create a duty. The duty to hold a passport comes from Article 9, and it reaches a product only through a delegated act for that product group.

As at August 2026, the Commission has adopted no delegated act for any product group. So the registry has an upload rule and no product to apply it to. Read how to read the timeline before you accept a date from a supplier.

The registry act is in force, and it still reaches no product

Implementing Regulation (EU) 2026/1778 lays down the arrangements for the registry. It has been in force since 6 August 2026, and this site has now read the full act.

The act creates registration duties. It sets no date of its own for any product. Article 1(1) lists the products it covers, and every entry sends you to another law.

Article 8(1) covers the first row. It ties the registration to the level that the applicable delegated acts set. This site searched the Official Journal and the Commission product group pages, and no adopted delegated act came back.

So a duty exists in an act that is in force, and today it reaches nobody. You have no registry duty today, so a registry service has nothing to upload.

The act does set three dates of its own. None of them reaches an exporter.

The registry accepts a company today, but it does not accept a product

A company can sign in and start work, but it cannot finish a passport registration.

A company can do four things now.

• Create an EU Login account, then sign in to the registry.
• Enrol an organisation, and give a legal name, an address and one identifier.
• Start the organisation verification, which needs a qualified electronic seal.
• Open a passport registration form for one product group, which is batteries.

Verification works in two steps. The Commission seals a declaration in PDF form. Your legal representative must then counter-sign or counter-seal that same file.

The seal must come from a qualified trust service provider. The Commission user guide points to the trusted list of the European Union and the European Economic Area. It also gives the address of that list.

The Commission user guide, version 1.01 of 28 July 2026, states:

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.

So no company can register a passport today, in any product group.

The act explains why that block exists. Article 8(7) makes the Commission read the passport content and check the semantic conformity of the data. Article 11(3) reads:

All data contained within a digital product passport shall be structured in accordance with the common data models and semantic definitions published in the semantic repository referred to in Article 12.

So an empty semantic repository for a product group stops a registration for that group. The Commission user guide reports that state for batteries. This site did not fetch the repository, so it repeats the guide and confirms nothing. See semantic data models.

An enrolment also changes no legal position. It creates no duty, and it removes none. Article 13(5) says the registry communication is not proof of compliance. Read that article again before you pay anybody to enrol you.

The seal requirement is law, and your EU importer keeps the upload duty

The seal requirement is law. It is not a choice the registry software made. The registry implementing act sets it, and the Commission user guide only describes it.

Article 4(2) gives a company acting as a legal person two ways to become a verified economic operator.

Point (b) is the paragraph that matters here. The act sets the same seal route for an operator that Union law does not require to be established in the Union. This site has read nothing about how a company outside the Union obtains an attestation of attributes, so it describes the seal alone.

Warning: read point (b) narrowly. Three limits apply to it.

• Recital 7 of the same act keeps other Union law on the place of establishment in force.
• Point (b) sets a verification method, and it does not decide who the responsible operator is.
• Article 13(4) of ESPR still attaches the upload to the operator that places the product on the market.

Recital 7 is the limit that matters most to you. It states that the use of the registry "should not circumvent or undermine" other Union law on the place of establishment. So your EU importer keeps the upload duty. See who is the economic operator.

This site read the eIDAS regulation, which is Regulation (EU) No 910/2014. It also read Regulation (EU) 2024/1183, which amends that regulation. It found no condition that the holder of a seal be established in the Union. The scope article of that regulation names the trust service provider.

Warning: that is a record of a search of two texts, and this site read them both. It is not a court judgment, and no second organisation was found that states it.

This site has not verified if a qualified trust service provider will issue a seal to a New Zealand company. Read this page as the law, and not as an answer to the market question. See what this site does not know.

Verification lasts three years at most

Article 4(4) of the registry implementing act reads:

Economic operators shall retain the status as verified economic operators until their electronic identification means expire but no longer than three years from the date of verification in accordance with paragraph 1 or 2.

So verification is not permanent. It ends when the certificate expires, or after three years, whichever comes first. Put a diary note against the date, because a lapsed verification stops the work that depends on it.

The registry has a helpdesk, and it keeps what you write to it

The Commission runs a helpdesk for the registry. It answers by email and by phone. Article 13(1) of the registry act sets the hours:

The helpdesk service shall operate year-round from 08:00 to 20:00 Brussels time.

This page gave the days as Monday to Friday until 15 August 2026. The act sets no days, so this page now gives none.

Warning: a message to the helpdesk is not private. Article 13(2) keeps written exchanges for six months after the request closes. It then makes them available to market surveillance authorities on request.

One technical document is published. It is the DPP Registry User Guide for Economic Operators, version 1.01 of 28 July 2026, from the Commission. The registry help page also links a question and answer file and a privacy statement.

This site found no published interface specification

The Commission news item of 20 July 2026 states:

Registration is available through either a secure user interface or an application programming interface (API), enabling economic operators to integrate registration into their existing digital systems where appropriate.

The registry act requires that interface. Article 3(b) lists an interface for machines as a component of the registry. Article 8(6) lets an operator register through the secure user interface, or through that interface.

A requirement is not a specification. Some suppliers read the sentence above as an offer you can build against today. This site looked for the specification on 15 August 2026, and found none.

Warning: this is a record of a search, and not a proof of absence. A specification may exist somewhere this site did not look. Do not buy an integration this year on the strength of a supplier claim. Ask the supplier for the address of the specification, and fetch it yourself.

This site fetched the live registry, the test registry, the registry help page, the Commission passport page and the user guide. The user guide has ten chapters and no chapter on an interface. The registry application carries no interface document and no address for one. The Commission passport page lists one item under technical guidelines, and that item is the user guide.

Article 13(4) puts the upload on the operator that places the product on the market

Article 13(4) reads:

The economic operator placing the product on the market or putting it into service shall upload, in the registry, the data referred to in paragraphs 1 and 2.

If you knit merino jumpers in New Zealand, you probably have no office in Europe. So the operator is usually the European importer. See who is the economic operator.

That does not remove your work. Your importer cannot upload an identifier that you never gave them. Agree in writing who creates the identifier, who uploads it, and who updates it after a change. See what a non-EU exporter must supply.

A registration identifier is not proof of compliance

The registry answers an upload with a unique registration identifier. Article 13(5) states that the communication from the registry "shall not be deemed to be proof of compliance with this Regulation or other Union law".

Some suppliers sell a registration as if it were compliance, but the law says it is not.

A registration identifier shows that a record reached the registry. It says nothing about the fibre content of your jumper, your test results or your declaration of conformity. See what a passport is not.

Proof of registration proves the registration, and nothing else

Warning: a supplier can show you a proof of registration and call it compliance. Two texts refuse that reading. ESPR Article 13(5) refuses it, and recital 16 of the registry act refuses it as well.

The registry act adds a document that ESPR does not mention. Article 9 lets an operator generate proof of registration at any time, for one passport or for many. The registrant downloads it as a secure electronic document.

Article 9(2) states the legal effect of that proof. The proof "shall serve as evidence, including vis-a-vis third parties, that the registration obligation for that digital product passport has been fulfilled".

Warning: read that sentence next to ESPR Article 13(5). The proof shows that you met the registration duty. It does not show that the product meets any other rule. Recital 16 of the registry act says the same thing, and it leaves the correctness of the data to the market surveillance authorities.

A qualified electronic seal of the Commission guarantees the proof. The proof then stays available for 90 calendar days from the day of generation. Recital 17 allows a new one after that.

The registry logs every change, and keeps the log

Article 14 makes the Commission run a log system with a complete and reliable audit trail. Four categories go into it, and each one has its own retention period.

Article 14(4) lets the Commission give the relevant logs to competent national authorities and to customs authorities. That happens in a suspected incident, and in an audit or a random security check.

So plan for a permanent record of your corrections. An authority can ask what you changed, and when you changed it. Keep your own record of why you changed it. See data accuracy and who carries the liability.

If the registry is down, the Commission records it

Article 15(2) requires the registry to be accessible at all times, except for necessary maintenance. Article 15(3) lets the Commission suspend it with no notice, for a malfunction, a cyber-attack or an urgent security need.

Article 15(4) matters on the day a date falls. Where an outage prevents a registration, the Commission records the date and time of that outage. It then makes that record available on request, for no less than five years.

That record shows that the registry was the cause, and not your company. Ask the operator that places your product on the market to keep the same note.

Your product data stays with you, not with the Commission

The registry stores identifiers and registration information, and not your detailed product data.

ESPR Article 10(c) requires the passport to be "stored by the economic operator responsible for its creation or by digital product passport service providers". Recital 41 requires "a decentralised data system".

So the registry entry holds the identifier. The care instructions for a merino jumper stay with the operator, or with the service provider that the operator pays. See how a passport works.

The registry is also not the public search page. Article 14 requires a publicly accessible web portal, where people can search and compare passport data. See the web portal.

Customs will get the registration identifier, but not yet

Article 15 covers customs controls for the passport. It requires the registration identifier to be given to customs.

That article applies only when two things are true. The registry must be operational, and a delegated act must cover the product. The first is now true. The second is true for no product group. See market surveillance and customs.

The registry act and the standards Decision are two different instruments

Two European instruments cover the digital product passport. Much commentary treats them as one instrument.

The Decision says nothing about the registry. It cites the six standards in the table below. See Implementing Decision (EU) 2026/1736.

Warning: this site has not read the six standards. Their texts are sold rather than published, so the table below gives a title and not a scope. See why the standard texts are paywalled.

There is no EN 18217 and no EN 18218. Do not write the six standards as a range.

Buy no registry upload service until an act covers your group

If you sell food or drink, the registry does not reach that product. ESPR Article 1(2) excludes food from the full regulation, and ESPR counts drink as food. The exclusion applies to the product, not to the company. Your other products can still fall inside ESPR. Your packaging falls under a separate law, Regulation (EU) 2025/40. See food and feed are excluded and packaging.

If you sell a jumper, a chair or a steel product, do not buy a registry upload service this year. No delegated act covers your product group, so there is nothing to upload.

If you sell an e-bike battery, your duty comes from a different law. That law is Regulation (EU) 2023/1542. It requires a battery passport from 18 February 2027, and it names three categories of battery.

Other batteries get a QR code to other information, not a passport.

A battery passport must also go into this registry. Article 1(1) of the registry act names batteries. Article 2 of the same act puts the point beyond doubt:

For the purposes of this Regulation, 'digital product passport' includes the battery passport established by Article 77 of Regulation (EU) 2023/1542.

So the first registration duty that reaches a real product is the battery duty. It arrives through the battery regulation, and not through the registry act. See batteries.

Everybody should do one thing. Name the company that will place your product on the European market, and write that name down. Article 13(4) attaches the upload to that company, and not to you.