Key development in the EU Digital Product Passport: launch of the DPP Registry

The European Commission has launched the Digital Product Passport (DPP) Registry, together with a testing environment bringing a key part of the EU’s DPP framework into operation for businesses placing products on the EU market.

Established under the Ecodesign for Sustainable Products Regulation (ESPR), the DPP is a digital record of key product information. It is designed to improve supply chain transparency, support informed consumer choices and make it easier to demonstrate compliance across the Single Market.

Product data itself stays decentralised, but economic operators must register each relevant DPP in the Registry. The Registry provides the secure infrastructure for registering unique product identifiers and associated metadata, so authorities and other stakeholders can verify that a DPP exists and access the relevant information.

The Registry also supports enforcement. Customs authorities can use it to check electronically that imported products have a valid registered DPP and that the commodity code has been provided before goods are released for free circulation, and market surveillance authorities can access registered DPPs for their own purposes. Registration data is automatically deleted from the Registry ten years after registration, unless other EU law sets a different period.

Scope of products

The Registry will support products covered by the ESPR including textiles, steel and aluminium, tyres, furniture, ICT products and energy-related products. It will also support product groups covered by other EU legislation requiring DPP registration, including certain large batteries, construction products, toys, detergents and end-user surfactants.

Clear rules for implementation

The Implementing Regulation sets clear rules for access management and user verification, the registration and storage of the required data, and the Registry’s technical architecture. Businesses can register through a secure user interface or an application programming interface (API), allowing registration to be integrated into their existing digital systems.

Economic operators can also request proof of registration in the form of a secure electronic document. This may be useful when demonstrating compliance to third parties, particularly in business-to-business transactions.

Design

The Registry is designed to make DPP registration simpler, rather than leaving each sector or business to develop its own approach. Businesses have free access to a semantic repository of standardised data models, definitions and vocabulary across product groups, helping them structure product information consistently, integrate DPP registration into existing systems and reduce the administrative burden as DPP requirements roll out.

Publication of DPP standards

In parallel with the launch of the Registry, DPP standards are being developed to help ensure that product passport information can be created, shared and accessed consistently across the EU. Six standards are already available, covering unique identifiers, data carriers, APIs, data exchange protocols and data storage. Businesses should factor in these standards when designing DPP processes, selecting technology providers and ensuring that product information works across different systems and markets.

Testing and implementation phases

The testing phase is intended to support a smooth rollout ahead of the first implementation deadline of 18 February 2027, which applies to certain large batteries. Economic operators can now access the testing environment, technical documentation, implementation guidance, webinars and updates via the new DPP website. A dedicated helpdesk is also available to support businesses through registration.

Key implications

The launch of the Registry is not, by itself, a new registration obligation. It puts in place the infrastructure that will support the phased rollout of DPP requirements. The immediate priority for businesses is to identify whether their products are likely to be in scope, when obligations may apply and whether their current data systems and service provider arrangements can support future registration. Early access to the Registry and the testing environment is encouraged. Technical solution providers supporting DPP registration and system integration; recyclers, repairers and other DPP data users may be interested in opportunities arising. 

Product-specific obligations will follow on a phased basis. In the meantime, businesses can use the testing environment and available guidance to assess their data readiness, assign internal responsibilities and prepare the processes needed for future DPP registration and compliance. 

Businesses should monitor product-specific rules under the ESPR and other sectoral legislation to understand which products are in scope, what information must be included and when registration will be required. They should also map relevant product data, identify who will be responsible for maintaining that data, and assess whether existing systems or service provider arrangements can support DPP creation and registration. As the first implementation deadline is 18 February 2027 for certain types of large batteries, there is limited time to finalise preparations.

Article co-authored by Jack Payne.