[{"data":1,"prerenderedAt":293},["ShallowReactive",2],{"pillar-eu-dpp-register-en":3},{"id":4,"title":5,"body":6,"description":262,"extension":263,"faq":264,"meta":283,"metaDescription":284,"metaTitle":285,"navigation":286,"path":287,"seo":288,"slug":289,"stem":290,"updated":291,"__hash__":292},"pillar_en\u002Fen\u002Fpillar\u002Feu-dpp-register.md","EU DPP registry: what applies since July 2026",{"type":7,"value":8,"toc":248},"minimark",[9,13,16,21,24,31,37,43,46,50,53,56,63,66,70,77,80,83,90,94,97,100,103,106,110,113,116,123,127,130,133,137,140,143,146,150,153,159,163,203,207,210,228,242],[10,11,12],"p",{},"The EU registry for digital product passports has been live since 20 July 2026. Anyone placing a product subject to the passport obligation on the EU market has to register the passport there, and be verified as an economic operator beforehand. For batteries this becomes relevant on 18 February 2027.",[10,14,15],{},"This page summarises what the registry is, what it is not, and which steps are due now.",[17,18,20],"h2",{"id":19},"what-applies-since-july-2026","What applies since July 2026",[10,22,23],{},"Three dates that are regularly mixed up in practice:",[10,25,26,30],{},[27,28,29],"strong",{},"16 and 17 July 2026:"," Implementing Regulation (EU) 2026\u002F1778 is adopted and published in the Official Journal. It governs identity verification, access management, the registration process, data models, versioning, logging and the registry's retention periods.",[10,32,33,36],{},[27,34,35],{},"20 July 2026:"," The Commission opens the production registry along with a separate test environment. Access is possible through a user interface and through an API.",[10,38,39,42],{},[27,40,41],{},"6 August 2026:"," The implementing regulation enters into force.",[10,44,45],{},"In parallel, Implementing Decision (EU) 2026\u002F1736 published six harmonised standards that set out data exchange, unique identifiers, data carriers and data storage in technical terms. Two further standards on security and reliability are still in preparation.",[17,47,49],{"id":48},"the-registry-launch-does-not-create-a-passport-obligation","The registry launch does not create a passport obligation",[10,51,52],{},"This is the most common misconception, and it costs companies either unnecessary panic or dangerous calm.",[10,54,55],{},"The fact that the registry is running obliges nobody to do anything. A product needs a digital product passport only once the relevant delegated act under the Ecodesign Regulation or a sector-specific rule requires it. The obligations arrive product group by product group.",[10,57,58,59,62],{},"For batteries the date is set: from ",[27,60,61],{},"18 February 2027",", electric vehicle batteries, batteries for light means of transport and industrial batteries above 2 kWh need a battery passport in order to be placed on the EU market. Further sectors follow, among them iron and steel and, later, construction products.",[10,64,65],{},"Anyone who does not manufacture or import batteries today therefore has time, but should keep the infrastructure question in view, because building the data base is the slow part, not the registration itself.",[17,67,69],{"id":68},"what-goes-into-the-registry-and-what-stays-with-you","What goes into the registry and what stays with you",[10,71,72,73,76],{},"The registry is an ",[27,74,75],{},"index, not a data store",". This distinction is decisive for the architecture of your solution.",[10,78,79],{},"What goes to Brussels are the unique identifiers, registration data and general metadata, plus an electronic timestamp and proof of integrity. Changes are versioned and logged. For certain registration data the regulation provides for storage of up to ten years, unless other Union law sets a different period.",[10,81,82],{},"The actual product data stays decentralised, either with the economic operator or with a DPP service provider. The registry only points to where the passport can be found. Legally and practically you remain responsible for the content.",[10,84,85,86,89],{},"The Ecodesign Regulation additionally requires a ",[27,87,88],{},"back-up copy held by an independent DPP service provider",", so that the passport stays available for the prescribed period even if your company or your provider no longer exists. Anyone planning an in-house build should factor this in early.",[17,91,93],{"id":92},"verification-as-an-economic-operator","Verification as an economic operator",[10,95,96],{},"Before you can register a passport at all, your company has to reach “verified” status in the registry. The proof runs through an electronic identification means notified under eIDAS.",[10,98,99],{},"In practice this means a natural person proves their identity electronically, and it must be shown that they are entitled to act for the legal person. For sole traders not established in the Union, the regulation instead provides for a qualified electronic signature based on a qualified certificate under Regulation (EU) No 910\u002F2014, or alternatively an electronic attestation of attributes issued under Union law. Legal persons not established in the EU are subject to separate identity requirements.",[10,101,102],{},"The verification process is a one-off. The status is valid until the identification means used expires and is tracked in the registry through status entries.",[10,104,105],{},"In practice this is exactly where companies get stuck, not because it is technically difficult, but because it is unclear who inside the company carries out the identification, whether the power of representation can be evidenced cleanly and which identification means is to be used at all. Settle this before the deadline pressure arrives.",[17,107,109],{"id":108},"the-level-at-which-registration-happens","The level at which registration happens",[10,111,112],{},"The registration level follows from the applicable product law: model, batch or item. Where several Union rules apply side by side, the most granular level prevails.",[10,114,115],{},"For batteries under the Battery Regulation this means item level: every single battery gets its own passport. That is a different scaling case from, say, a piece of furniture at model level, and it should feed into the assessment of any solution.",[10,117,118,119,122],{},"On the product identifier: the registry requires the product identifier and registration level foreseen by the applicable Union law. The Ecodesign Regulation relies on the ISO\u002FIEC 15459 series of standards and allows an “or equivalent” approach. A GTIN, and with it a GS1 membership, is ",[27,120,121],{},"not"," universally prescribed, even though it is a workable anchor between the physical product and the passport in many cases. Anyone already selling through retail or marketplaces usually has GTINs anyway.",[17,124,126],{"id":125},"registration-is-not-proof-of-conformity","Registration is not proof of conformity",[10,128,129],{},"The Ecodesign Regulation separates registration and conformity explicitly. A registration identifier or an electronic proof of registration shows that a registration took place, nothing more. Whether your product meets the substantive requirements is a separate question.",[10,131,132],{},"The shortcut “registered, therefore compliant” is widespread and expensive in a market surveillance situation.",[17,134,136],{"id":135},"customs-and-market-surveillance","Customs and market surveillance",[10,138,139],{},"Authorities receive role-based access. Market surveillance authorities can see what they need for their purposes; customs are to be able to check electronically whether an imported product has a validly registered passport before it is released.",[10,141,142],{},"The timing is not yet sharp: the entry into force of the implementing regulation starts the four-year period within which the Commission has to link the registry to the EU customs single window CERTEX (Art. 15(3) ESPR). As long as that link is not in place, no automatic check happens at the border.",[10,144,145],{},"For importers this means the control pressure at the customs border rises gradually, while the obligation itself applies in full from the respective cut-off date.",[17,147,149],{"id":148},"delegating-the-registration","Delegating the registration",[10,151,152],{},"You do not have to carry out the registration yourself. The economic operator can delegate the registration activities to a third party.",[10,154,155,156,158],{},"What is ",[27,157,121],{}," transferable is the legal responsibility. It stays in every case with the company placing the product on the market. A service provider can support the verification, take on the technical connection and execute the registrations, but cannot be liable in your place.",[17,160,162],{"id":161},"what-makes-sense-now","What makes sense now",[164,165,166,173,179,185,191,197],"ol",{},[167,168,169,172],"li",{},[27,170,171],{},"Establish exposure."," Which of your products fall under the passport obligation from February 2027? Do you place the finished product on the market yourself, or do you supply components?",[167,174,175,178],{},[27,176,177],{},"Assign ownership internally."," Who owns the passport: quality management, product management, IT? Without a named person, nothing happens before January.",[167,180,181,184],{},[27,182,183],{},"Prepare verification as an economic operator."," Identification means, power of representation, acting person. This is the step with the longest lead time and the least effort.",[167,186,187,190],{},[27,188,189],{},"Survey your data gaps."," Which of the required details are available internally, which have to be requested from suppliers? Experience shows this is the critical path: supplier enquiries across several tiers take months, not weeks.",[167,192,193,196],{},[27,194,195],{},"Set the registration level and product identifier."," For batteries that is item level. Does your existing serial number system fit?",[167,198,199,202],{},[27,200,201],{},"Use the test environment."," The separate test environment exists for exactly this.",[17,204,206],{"id":205},"support-from-biberware","Support from Biberware",[10,208,209],{},"We handle the registration as a delegated third party and connect you to the registry technically. This is not a separate package but part of the one-off €2,500 onboarding:",[211,212,213,216,219,222,225],"ul",{},[167,214,215],{},"eIDAS identification of your company",[167,217,218],{},"Registration as a verified economic operator in the EU DPP registry",[167,220,221],{},"Creation of your product identifiers at the applicable registration level",[167,223,224],{},"Specification of the data carrier, optionally as a QR code following GS1 Digital Link",[167,226,227],{},"Documentation for your internal records and for market surveillance",[10,229,230,231,236,237,241],{},"The same onboarding produces the data model and supplier connection for the complete battery passport by 18 February 2027. Operation then starts at €119 per month, with unlimited product passports. Details on the ",[232,233,235],"a",{"href":234},"\u002Fen\u002Fpricing","pricing page"," and on our ",[232,238,240],{"href":239},"\u002Fen\u002Fbattery-passport","battery passport page",".",[10,243,244],{},[245,246,247],"em",{},"Last updated: August 2026. This text is editorial guidance, not legal advice. Deadlines and scope are specified further by delegated and implementing acts and may change; only the respective legal act in its applicable version is binding.",{"title":249,"searchDepth":250,"depth":250,"links":251},"",2,[252,253,254,255,256,257,258,259,260,261],{"id":19,"depth":250,"text":20},{"id":48,"depth":250,"text":49},{"id":68,"depth":250,"text":69},{"id":92,"depth":250,"text":93},{"id":108,"depth":250,"text":109},{"id":125,"depth":250,"text":126},{"id":135,"depth":250,"text":136},{"id":148,"depth":250,"text":149},{"id":161,"depth":250,"text":162},{"id":205,"depth":250,"text":206},"The European Commission's central registry for digital product passports has been live since 20 July 2026. Who has to register, how verification as an economic operator works and what goes into the registry.","md",[265,268,271,274,277,280],{"q":266,"a":267},"Do we have to register already?","Only if a passport obligation already applies to your product. The launch of the registry alone obliges nobody. For batteries the obligation starts on 18 February 2027.",{"q":269,"a":270},"Does the EU store our product data?","No. What goes into the registry are unique identifiers, registration data and metadata. The product data itself stays decentralised with you or your service provider.",{"q":272,"a":273},"Do we need a GS1 membership?","Not necessarily. What counts is the identifier foreseen by the applicable product law; the Ecodesign Regulation allows equivalent schemes under ISO\u002FIEC 15459. A GTIN is a common route, but not a prescribed one.",{"q":275,"a":276},"Can a service provider handle the registration for us?","Yes. The registration activities can be delegated. The legal responsibility stays with you as the party placing the product on the market.",{"q":278,"a":279},"Does a completed registration mean our product is compliant?","No. The Ecodesign Regulation separates registration and conformity explicitly.",{"q":281,"a":282},"What happens if we have no passport on the cut-off date?","Without a valid battery passport, the battery may not be placed on the EU market from 18 February 2027. In practice that is a ban on selling the affected products.",{},"The EU DPP registry has been live since July 2026. Who has to register, how operator verification works and what goes into it.",null,true,"\u002Fen\u002Fpillar\u002Feu-dpp-register",{"title":5,"description":262},"eu-dpp-register","en\u002Fpillar\u002Feu-dpp-register","2026-08-18","Wjs3k2BNlGyCRRM_km2KMwwpR7uWjF_D-XAuw9Zdd5c",1787840218321]