EU Digital Product Passport (DPP) 2026: Registry, Requirements & Deadlines

The European Union has reached a major milestone in the implementation of the Digital Product Passport (DPP).

On 20 July 2026, the European Commission officially launched the Digital Product Passport Registry, together with a testing environment for businesses. The Registry provides the central EU infrastructure through which Digital Product Passports will be registered as DPP requirements are progressively introduced for different product groups.

The launch follows the adoption of Commission Implementing Regulation (EU) 2026/1778 of 16 July 2026, which establishes the implementation arrangements for the Registry created under Regulation (EU) 2024/1781, the Ecodesign for Sustainable Products Regulation (ESPR).

This is an important step towards making Digital Product Passports operational across the European Single Market. However, it does not mean that every consumer product sold in the EU already requires a DPP.

The DPP framework is being introduced progressively. The exact requirements, information fields, registration level and application date depend on the product category and the EU legislation applicable to it.

For manufacturers, importers, brands and online sellers, the important development is that the technical infrastructure is no longer theoretical. The EU Registry is now operational, the first harmonised DPP standards have been published, and the first mandatory product-specific implementation deadline is approaching.

What is the Digital Product Passport?

A Digital Product Passport (DPP) is a structured digital record containing information relating to a product, component or material.

The legal foundation for the general EU DPP framework is the Ecodesign for Sustainable Products Regulation, Regulation (EU) 2024/1781 (ESPR).

Under the ESPR, a Digital Product Passport is defined as a set of product-specific data containing the information required by the applicable delegated act and accessible electronically through a data carrier.

The objective is to make relevant product information available in a standardised and interoperable digital format throughout the product lifecycle.

Depending on the legislation and product category, a DPP may eventually contain information concerning matters such as:

• product identification;
• manufacturer and economic operator information;
• materials and composition;
• substances of concern;
• environmental performance;
• durability;
• repairability;
• maintenance;
• spare parts;
• recycled content;
• recyclability;
• disassembly;
• reuse and remanufacturing;
• waste treatment;
• safety and compliance information;
• technical documentation; and
• other product-specific regulatory information.

Not every DPP will contain the same information. The precise data requirements will be established through the legislation applicable to the particular product group.

The Commission describes the DPP as a digital container designed to improve transparency, circularity and legal compliance while providing businesses, consumers, repairers, recyclers and public authorities with more reliable access to product information.

The Digital Product Passport is not simply a QR code

One common misunderstanding is that the Digital Product Passport is essentially an EU-mandated QR code.

That is too simplistic.

A QR code may be used as a data carrier, but the DPP is the underlying structured digital information system.

The overall architecture can be understood as several connected elements:

1. The physical product is associated with a unique product identifier.
2. A data carrier provides access to the Digital Product Passport.
3. The detailed DPP information is maintained electronically.
4. The relevant DPP is registered in the EU Digital Product Passport Registry.
5. The Registry generates a unique registration identifier.
6. Different users receive access to the information permitted for their respective roles.

Depending on the applicable product-specific legislation, the data carrier may be placed on the product itself, its packaging or accompanying documentation.

The exact placement and level of identification will therefore need to be checked against the legislation applicable to the relevant product category. Similar distinctions are already important under the EU's GPSR labelling requirements.

What happened on 20 July 2026?

On 20 July 2026, the European Commission announced that the Digital Product Passport Registry was live.

According to the Commission, the launch represents an important milestone in making the DPP a practical system for businesses placing products on the EU market.

The Commission simultaneously made available a testing environment, allowing businesses and other relevant actors to explore DPP registration processes without affecting live registrations.

The operational Registry follows Commission Implementing Regulation (EU) 2026/1778, adopted on 16 July 2026 and published in the Official Journal on 17 July 2026.

The Regulation establishes detailed rules covering matters including:

• Registry architecture;
• access management;
• user identification and verification;
• organisation and user management;
• DPP registration;
• registration data;
• registration evidence;
• version management;
• semantic data models;
• logging;
• security;
• data retention;
• responsibilities of verified economic operators;
• access by competent authorities; and
• technical operation of the Registry.

The launch therefore marks the transition from the legislative design of the DPP infrastructure towards an operational EU registration system.

What exactly is the DPP Registry?

The Registry should not be confused with the Digital Product Passport itself.

The EU has deliberately adopted a decentralised architecture.

The complete product information contained in a DPP does not necessarily sit inside one large Commission database. Instead, the detailed DPP data can remain under the responsibility of the relevant economic operator or a DPP service provider.

The DPP Registry functions primarily as the EU-level indexing and registration infrastructure.

According to the European Commission, it stores unique identifiers, registration information and high-level metadata rather than necessarily storing the complete detailed contents of every DPP.

This distinction is important.

A simplified model is:

Physical product → data carrier → Digital Product Passport → registration in EU Registry

The Registry provides the EU-level mechanism that connects registered products with the wider DPP infrastructure.

What does the Registry contain?

Article 3 of Commission Implementing Regulation (EU) 2026/1778 establishes the technical structure of the Registry.

It includes:

• a secure website interface;
• an API for DPP registration and communication with the Registry;
• a verification platform;
• a system for generating unique registration identifiers;
• storage for required identifiers and, where applicable, commodity codes;
• information relating to verified DPP service providers;
• a semantic repository;
• a logging system; and
• identification and authorisation systems for Registry users.

This architecture is designed to support both companies carrying out registrations manually and businesses integrating DPP registration into larger product information or compliance systems.

Registration through the interface or API

Economic operators can register DPPs through either:

• the Registry's secure user interface; or
• an Application Programming Interface (API).

This is particularly important for larger manufacturers and retailers.

A company managing only a limited number of product types may be able to use the web interface directly. A multinational company managing thousands or millions of products, batches or individual items may instead need automated communication between its Product Information Management (PIM), Enterprise Resource Planning (ERP), Product Lifecycle Management (PLM) or compliance systems and the EU Registry.

The DPP should therefore increasingly be viewed as a product data governance issue, not merely a labelling exercise.

Who will be responsible for registering a DPP?

For products governed by the ESPR, Implementing Regulation (EU) 2026/1778 provides that the DPP is registered by a verified economic operator placing the product on the market or putting it into service.

Other EU legislation introducing a DPP may identify the relevant responsible actor separately.

Depending on the legislation and supply chain structure, relevant economic operators may include:

• manufacturers;
• importers;
• authorised representatives;
• distributors;
• dealers;
• fulfilment service providers; and
• other actors assigned responsibilities under the applicable legislation.

The Commission states that primary responsibility for DPP creation and accuracy rests with the economic operators placing the relevant products on the EU market.

This makes supply-chain role allocation particularly important.

A non-EU manufacturer, EU importer, brand owner and fulfilment provider should not assume that another party will automatically manage the DPP. Responsibilities should be established before the relevant product is placed on the EU market. For general consumer products, businesses should similarly understand the role of the GPSR Responsible Person where applicable.

Economic operators must be verified

Access to the Registry for registration purposes is subject to verification.

Commission Implementing Regulation (EU) 2026/1778 establishes verification requirements for economic operators, including businesses established outside the European Union.

Once successfully verified, an economic operator receives verified status for Registry purposes.

That status does not remain valid indefinitely. Under the Implementing Regulation, verification lasts until the relevant electronic identification means expires, but no longer than three years from verification, whichever occurs first.

After expiration, the operator must successfully repeat the identity verification process before it can register new DPPs or modify relevant Registry information.

Companies should therefore include DPP Registry account governance in their compliance procedures rather than treating registration as a one-time administrative exercise.

Model, batch or individual item level?

A particularly important feature of the DPP framework is granularity.

A Digital Product Passport may be required at:

• model level;
• batch level; or
• individual item level.

The applicable level will be specified by the relevant delegated act or other EU legislation.

This can have a major impact on implementation costs and technical architecture.

A model-level passport could potentially cover large quantities of identical products.

A batch-level system requires additional production traceability.

An item-level system can require every individual physical product to have a unique identity linked to its own passport.

Implementing Regulation (EU) 2026/1778 also addresses situations in which multiple pieces of EU legislation apply to the same product. Where different rules require DPP registration at different levels of granularity, registration must take place at the most granular level required by the applicable legislation.

Where an item-level DPP is required and batch and model identifiers exist, those identifiers must be linked. Similarly, a batch-level DPP must be linked to the relevant model identifier where such a model exists.

For manufacturers, this means that product identification architecture will become an important component of regulatory compliance.

What happens when a DPP is registered?

Registration is more than simply submitting a website address.

Under Implementing Regulation (EU) 2026/1778, the Commission's system performs automated checks during registration.

Depending on the applicable legislation, these checks can include:

• semantic conformity of the DPP data;
• consistency between mandatory Registry data and information contained in the DPP;
• compliance with the required granularity level;
• validity of the relevant commodity code; and
• where applicable, links to backup arrangements provided through a DPP service provider.

This illustrates one of the most important developments created by the DPP framework.

EU product compliance is gradually moving towards structured, machine-readable and automatically verifiable regulatory data.

The Unique Registration Identifier

After the required information has been uploaded, the Registry generates a unique registration identifier associated with the relevant product identifiers.

This identifier has an important regulatory function.

Under Article 13 of the ESPR, the Registry automatically communicates the unique registration identifier to the economic operator following registration.

However, the ESPR expressly clarifies that receiving this identifier does not constitute proof that the product complies with EU law.

That distinction should not be overlooked.

DPP registration demonstrates that the required registration process has taken place. It does not replace:

• conformity assessment;
• safety assessment;
• technical documentation;
• required testing;
• CE marking where applicable;
• declarations of conformity;
• chemical compliance;
• labelling obligations; or
• other substantive product requirements.

A registered product can still be non-compliant.

Proof of registration

The 2026 Implementing Regulation also introduces formal proof of registration.

The proof is generated as a secure electronic document and may contain information including:

• the unique product identifier;
• the commodity code where relevant;
• the identity of the verified economic operator responsible for registration;
• the registration date and time; and
• a cryptographic hash associated with the relevant version of the DPP.

The proof is protected using a qualified electronic seal and Commission electronic timestamp.

The economic operator can obtain it through the secure Registry interface or API.

The generated proof remains available through the Registry for 90 calendar days from its generation, and can be regenerated where necessary.

Businesses should consider incorporating this registration evidence into their product compliance and technical documentation procedures.

DPP information must remain accurate

DPP compliance does not end when the initial registration is completed.

Verified economic operators are responsible for ensuring that information stored in the Registry remains:

• accurate;
• complete; and
• up to date.

The Registry supports versioning and records timestamps for updates.

Changes to registration information are logged.

This means companies need procedures for determining when product changes require corresponding DPP updates.

Examples could include changes to:

• materials;
• components;
• suppliers;
• manufacturing locations;
• product specifications;
• repair information;
• substances;
• environmental data;
• regulatory information; or
• economic operator details.

The precise consequences of a product change will depend on the applicable product-specific requirements.

Data retention

Where the relevant EU legislation does not establish another specific DPP availability period, Implementing Regulation (EU) 2026/1778 provides for DPP registration data to be automatically deleted from the Registry 10 years after registration.

Where sector-specific EU legislation establishes another period, the Registry retention period is aligned with that requirement.

Businesses should therefore distinguish between:

• the availability of the DPP itself;
• information maintained by the economic operator;
• information stored in the EU Registry; and
• other technical documentation retention obligations.

These periods may not always be identical.

The Registry creates an audit trail

The Registry includes a logging system intended to provide a complete and reliable audit trail.

Logged activities include categories such as:

• authentication and access;
• data modifications;
• account and permission changes;
• administrative actions; and
• data exchanges.

Different retention periods apply to different categories of logs.

This infrastructure gives competent authorities considerably stronger tools for determining not only what information is currently registered, but also how registration information has been managed over time.

The semantic repository

Another important part of the Registry is the DPP semantic repository.

This will provide authoritative, machine-readable definitions and data models used across Digital Product Passports.

Its purpose is to make DPP information interoperable.

Without common semantic definitions, two companies could technically provide the same information but describe it in incompatible ways. That would severely limit automated data exchange.

The semantic repository therefore supports harmonisation of:

• data attributes;
• terminology;
• data structures;
• relationships between DPPs;
• links between DPP information and supporting evidence; and
• product-specific data models.

This is particularly important for businesses developing their own DPP software or integrating third-party DPP providers into existing IT systems.

Six harmonised DPP standards have now been published

The technical framework advanced significantly in July 2026 with Commission Implementing Decision (EU) 2026/1736 of 14 July 2026.

The Decision published references to six harmonised European standards supporting the Digital Product Passport framework:

• EN 18216:2026 (Digital product passport, Data exchange protocols)
• EN 18219:2026 (Digital product passport, Unique identifiers)
• EN 18220:2026 (Digital product passport, Data carriers)
• EN 18221:2026 (Digital product passport, Data storage, archiving and persistence)
• EN 18222:2026 (Digital Product Passport, Application Programming Interfaces (APIs) for product passport lifecycle management and searchability)
• EN 18223:2026 (Digital Product Passport, System interoperability)

These standards provide an important part of the common technical foundation needed for interoperable DPP systems across the European Union.

Under Article 41 of the ESPR, conformity with relevant harmonised standards whose references have been published in the Official Journal can provide a presumption of conformity with the corresponding requirements covered by those standards.

The Commission has indicated that the remaining DPP standardisation work will continue.

DPP and customs controls

One of the most consequential parts of the Digital Product Passport framework concerns imports.

Article 15 of the ESPR establishes a direct relationship between DPP registration and EU customs controls.

For products covered by the relevant DPP requirements, a person intending to place a product under the customs procedure release for free circulation must provide or make available the product's unique registration identifier to customs.

Customs authorities will ultimately be able to verify electronically that:

• the unique registration identifier corresponds with the Registry information; and
• the commodity code corresponds with the registered data.

The Commission is required to interconnect the DPP Registry with the EU Customs Single Window Certificates Exchange System (EU CSW-CERTEX).

This is intended to enable automated information exchange between the Registry and national customs systems.

The ESPR requires this interconnection to become operational within four years following the entry into force of the Registry implementing rules.

For importers, this is a major development.

The DPP is therefore not merely a consumer information initiative. It is being incorporated into the EU's market access and enforcement infrastructure. Businesses planning to introduce consumer products into Europe should consider DPP readiness as part of their broader EU product compliance strategy.

Customs clearance is not proof of compliance

There is another important legal distinction.

Even when customs verifies the relevant DPP registration information and releases a product for free circulation, that release does not constitute proof of compliance with EU product legislation.

Market surveillance authorities retain their powers.

A product can therefore:

• possess a registered DPP;
• pass the relevant customs DPP check; and
• still be found non-compliant during a market surveillance investigation.

The underlying product compliance assessment remains essential.

Market surveillance authorities will use DPP information

The Registry also supports access by national competent authorities.

Market surveillance authorities can use registered information and DPP data for enforcement purposes.

This should make product investigations more data-driven and could allow authorities to identify discrepancies between:

• the physical product;
• its labelling;
• technical documentation;
• economic operator information;
• customs information; and
• registered DPP data.

Companies should therefore ensure that their DPP is consistent with the rest of their compliance documentation.

The DPP should not become a separate marketing database containing claims that cannot be substantiated by the underlying technical file. The EU's existing Safety Gate framework also demonstrates the increasing importance of structured regulatory information for market surveillance.

Is a DPP mandatory for every product from 20 July 2026?

No.

This is perhaps the most important point for businesses following the Registry launch.

The fact that the EU Registry became operational on 20 July 2026 does not mean that all products placed on the EU market require a DPP from that date.

The ESPR is a framework regulation.

Product-specific requirements are introduced progressively through delegated acts. Other EU regulations can also establish DPP requirements independently.

The Commission states that, following adoption of ESPR delegated acts, economic operators will generally have a transition period of at least 18 months.

Businesses therefore need to monitor the legislation applicable to their specific product category rather than applying a single universal DPP deadline.

Which products will require Digital Product Passports?

The DPP infrastructure is designed to support products covered by the ESPR as well as product passports introduced under other EU legislation.

The Commission identifies product areas including:

• textiles;
• iron and steel;
• aluminium;
• tyres;
• furniture;
• ICT products;
• energy-related products;
• certain batteries;
• construction products;
• toys;
• detergents; and
• surfactants.

The legal basis, implementation date and required DPP contents can differ significantly between these categories.

Batteries: the first major mandatory deadline

The most immediate mandatory DPP deadline concerns batteries.

Under Article 77 of Regulation (EU) 2023/1542, the EU Batteries Regulation, from 18 February 2027 a battery passport will be required for:

• each light means of transport (LMT) battery;
• each industrial battery with a capacity greater than 2 kWh; and
• each electric vehicle battery

placed on the EU market or put into service.

The battery passport contains both battery-model information and information specific to the individual battery.

The Batteries Regulation also establishes different access rights for different categories of information.

This means the DPP framework is not based on the assumption that every person should have access to every piece of product data.

Certain information can be publicly accessible, while other information may be restricted to authorities, notified bodies or persons with a legitimate interest.

Textiles and apparel

Textiles are one of the most closely watched product groups under the ESPR.

The Commission's Ecodesign for Sustainable Products and Energy Labelling Working Plan 2025-2030 identifies textiles/apparel as a priority product group and gives 2027 as the indicative timeline for adoption of the relevant ecodesign measure.

The Commission's current DPP timeline similarly indicates sector-specific DPP requirements for textiles in the Q3-Q4 2027 period.

This does not mean that every garment automatically needs a DPP in 2027.

The relevant delegated act must first be adopted, and the Commission states that ESPR delegated acts will provide economic operators with a transition period of at least 18 months.

For apparel brands, however, the direction is now clear enough that preparation should already begin.

Fashion companies should start assessing whether they can reliably collect structured information on matters such as:

• fibre and material composition;
• suppliers;
• manufacturing locations;
• product identifiers;
• substances and chemical compliance;
• recycled material claims;
• repair and care information;
• durability information;
• recyclability;
• supporting evidence; and
• lifecycle-related product information.

The exact mandatory data points will depend on the final textile-specific delegated act.

What about footwear?

Footwear requires particular care.

The Commission's first ESPR Working Plan gives priority specifically to textiles/apparel, while the wider market analysis refers to textiles and footwear.

Businesses should therefore avoid assuming that footwear will automatically follow precisely the same implementation date and DPP requirements as apparel.

The final scope must be determined from the relevant delegated act once adopted.

Footwear manufacturers should nevertheless begin improving material and supplier traceability because complex multi-material products are particularly dependent on reliable upstream supply-chain information.

Construction products

The revised Construction Products Regulation, Regulation (EU) 2024/3110, establishes its own construction Digital Product Passport framework.

The construction DPP system is required to be compatible and interoperable with the broader DPP architecture created under the ESPR.

Construction product passports can include extensive information, including:

• declarations of performance and conformity;
• general product information;
• instructions;
• safety information;
• technical documentation;
• labels;
• unique identifiers; and
• documentation required under other applicable EU legislation.

This demonstrates how the EU intends the DPP architecture to function across multiple regulatory regimes rather than remaining limited to the ESPR.

Online marketplaces and distance selling

The DPP will also affect e-commerce.

The Commission states that where products are placed on the EU market through distance selling, online marketplaces will need to make relevant DPP information accessible.

Manufacturers and sellers should therefore plan for DPP integration not only on physical products but also within their digital sales architecture.

This could affect:

• online product detail pages;
• marketplace listings;
• product feeds;
• retailer databases;
• QR codes and other data carriers;
• digital catalogues; and
• product information management systems.

For businesses selling through Amazon, marketplaces, direct-to-consumer websites or omnichannel retailers, DPP implementation should therefore involve both compliance and e-commerce teams. Businesses selling through Amazon can also review our guide to Amazon EU sales and GPSR compliance.

How does the DPP interact with GPSR compliance?

For general consumer products, the Digital Product Passport should not be confused with the General Product Safety Regulation (EU) 2023/988 (GPSR).

The two regimes have different legal purposes.

GPSR addresses the safety of consumer products and establishes obligations concerning matters such as:

• product safety;
• risk assessment;
• technical documentation;
• traceability;
• manufacturer information;
• responsible economic operators;
• warnings and instructions;
• accident reporting;
• corrective actions; and
• market surveillance.

The DPP framework is broader and is particularly focused on structured digital product information, sustainability, circularity, traceability and regulatory data exchange.

Where both regimes apply, companies will need to ensure that the information is consistent.

A Digital Product Passport should therefore be built on reliable compliance documentation rather than developed independently from the technical file.

DPP does not replace existing compliance documentation

The DPP should not be viewed as a substitute for existing regulatory documentation.

Depending on the product, businesses may still require documentation such as:

• technical files;
• risk assessments;
• declarations of conformity;
• test reports;
• chemical compliance evidence;
• safety data;
• instructions;
• warnings;
• product specifications;
• Bills of Materials;
• supplier declarations; and
• traceability records.

Instead, the DPP increasingly becomes the digital interface through which selected product information can be structured, linked, accessed and verified.

The quality of the DPP will therefore depend heavily on the quality of the underlying compliance documentation.

What should manufacturers do now?

Even where a product-specific DPP obligation has not yet taken effect, manufacturers should not wait until the final application date to examine their data.

A practical preparation programme should include the following steps.

1. Determine whether your products are likely to fall within an upcoming DPP regime

Map the portfolio against:

• the ESPR Working Plan;
• existing sector legislation;
• upcoming delegated acts;
• battery requirements;
• construction product requirements; and
• other sector-specific EU legislation.

2. Map the supply chain

Identify:

• legal manufacturer;
• manufacturing facilities;
• component suppliers;
• material suppliers;
• EU importer;
• authorised representative where applicable;
• distributors;
• fulfilment providers;
• online marketplaces; and
• relevant DPP service providers.

3. Establish reliable product identification

Review how products are identified at:

• model level;
• batch level; and
• individual item level.

Product identification should be capable of supporting the granularity eventually required by applicable legislation.

4. Review the Bill of Materials

A structured BOM is likely to become increasingly important.

Businesses should know:

• what materials are used;
• which components contain them;
• where the components originate;
• who supplied them;
• what compliance evidence exists; and
• whether relevant information can be provided digitally.

5. Organise supplier documentation

Supplier data should be collected systematically rather than through scattered email chains.

Relevant documentation may include:

• material specifications;
• declarations;
• test reports;
• chemical compliance information;
• certificates;
• recycled-content evidence;
• sustainability data; and
• manufacturing information.

6. Review environmental and sustainability claims

Any information eventually placed in a DPP must be reliable.

Claims concerning recycled content, recyclability, durability, repairability, environmental performance or materials should be supported by appropriate evidence.

7. Review IT architecture

Determine where product data currently resides.

Relevant systems may include:

• ERP;
• PIM;
• PLM;
• quality management systems;
• compliance databases;
• supplier portals;
• traceability systems; and
• e-commerce platforms.

Businesses with large portfolios should consider whether API-based DPP registration will ultimately be required.

8. Define ownership

DPP compliance crosses traditional departmental boundaries.

Responsibility may involve:

• regulatory affairs;
• product compliance;
• sustainability;
• quality;
• procurement;
• IT;
• logistics;
• legal;
• e-commerce; and
• product development.

A clear internal owner should coordinate implementation.

9. Use the Commission's testing environment

The European Commission now provides a DPP Registry testing environment.

Companies expecting to fall within early DPP requirements can use this environment to become familiar with registration processes before mandatory implementation.

Why businesses should prepare before the legal deadline

The difficult part of DPP implementation is unlikely to be generating a QR code.

The real challenge is creating a reliable chain of structured product information.

A company may discover that essential information is:

• held only by suppliers;
• stored in incompatible systems;
• available only in PDFs;
• inconsistent between departments;
• not linked to specific product identifiers;
• unavailable at batch or item level;
• unsupported by documentary evidence; or
• difficult to maintain throughout the product lifecycle.

These issues cannot always be solved shortly before a compliance deadline.

For manufacturers with large portfolios, the transition to DPP compliance can require changes to supplier contracts, product master data, labelling systems, packaging, IT infrastructure and compliance procedures.

A major change in EU product compliance

The operational launch of the Digital Product Passport Registry represents more than the introduction of another EU database.

It is part of a broader shift in European product regulation towards digitally accessible, structured and machine-readable compliance information.

Traditionally, much of product compliance has depended on documents stored internally and provided to authorities when requested.

The DPP model moves towards a system in which product information can be digitally connected to the physical product and accessed by relevant actors throughout its lifecycle.

Combined with future customs integration, market surveillance access and standardised product identifiers, this has the potential to significantly change how compliance is verified in the European Union. The same broader enforcement environment is already visible through the EU Safety Gate system, product recalls and increasing market surveillance activity.

The important dates

Businesses should currently keep the following milestones in mind:

• 28 June 2024: Regulation (EU) 2024/1781 (ESPR) published.
• 16 April 2025: Commission adopts the first ESPR and Energy Labelling Working Plan 2025-2030.
• 14 July 2026: Commission adopts Implementing Decision (EU) 2026/1736 concerning the first six harmonised DPP standards.
• 16 July 2026: Commission adopts Implementing Regulation (EU) 2026/1778 establishing implementation arrangements for the DPP Registry.
• 17 July 2026: Implementing Regulation (EU) 2026/1778 published in the Official Journal.
• 20 July 2026: EU Digital Product Passport Registry becomes operational.
• 18 February 2027: Battery passports become mandatory for LMT batteries, industrial batteries above 2 kWh and electric vehicle batteries covered by the Batteries Regulation.
• 2027: Textiles/apparel are currently scheduled for adoption of product-specific ESPR requirements, subject to the legislative process.
• Following product-specific delegated acts: economic operators will generally receive a transition period of at least 18 months before the relevant ESPR requirements apply.

The Commission's DPP roadmap remains indicative for future delegated acts and should be monitored as legislation develops.

What the Registry launch does not mean

To avoid unnecessary compliance work, businesses should keep four distinctions in mind:

The Registry being operational does not mean all products need a DPP today.

Having a DPP does not prove that a product complies with EU law.

Having a DPP does not replace the technical file, risk assessment, testing or other product-specific compliance requirements.

A QR code alone is not a compliant Digital Product Passport.

The actual obligation depends on the product, the applicable EU legislation and the relevant application date.

How EaseCert can help

For manufacturers, brands and online sellers, preparing for Digital Product Passports should begin with the underlying product compliance information.

EaseCert supports businesses in organising the technical and regulatory documentation needed to place consumer products on the European market.

For companies preparing for future DPP obligations, this can include reviewing and structuring information such as:

• product identification;
• manufacturer and economic operator information;
• Bills of Materials;
• supplier documentation;
• technical documentation;
• risk assessments;
• test reports;
• declarations of conformity;
• chemical compliance evidence;
• traceability information;
• product labelling; and
• supporting regulatory documentation.

The objective is to establish a reliable compliance data foundation that can subsequently support product-specific DPP requirements as they become mandatory.

Businesses in sectors such as textiles, apparel, footwear, furniture, batteries, electrical products and other priority product groups should already be monitoring the development of the applicable delegated acts and assessing the quality of their product data.

The EU Digital Product Passport has moved from policy development towards practical implementation. The Registry is now operational. The technical standards are being established. Product-specific requirements are following.

For many manufacturers, the most useful step now is not to create a QR code, but to make sure the information behind that future QR code is complete, accurate, traceable and supported by evidence.

Companies preparing to launch products in Europe can also use our 2026 EU product launch checklist to review the wider compliance requirements that may apply alongside future DPP obligations.

Official EU Sources and References

This article is based primarily on official European Union legislation and European Commission guidance. The following sources provide the legal and regulatory basis for the information above:

1. European Commission, “The Digital Product Passport Registry is now live”, 20 July 2026.
   Official European Commission announcement confirming the operational launch of the Digital Product Passport Registry and testing environment.
   European Commission
2. Regulation (EU) 2024/1781 of the European Parliament and of the Council of 13 June 2024 establishing a framework for the setting of ecodesign requirements for sustainable products (ESPR).
   This Regulation establishes the general legal framework for Digital Product Passports, including the DPP system, Registry, unique identifiers, customs interaction and product-specific delegated acts.
   EUR-Lex: Regulation (EU) 2024/1781
3. Commission Implementing Regulation (EU) 2026/1778 of 16 July 2026 laying down the implementation arrangements for the Digital Product Passport Registry.
   This Regulation establishes the operational rules governing the Registry, including architecture, registration, economic operator verification, registration evidence, APIs, security, logging, data retention and semantic data models.
   EUR-Lex: Commission Implementing Regulation (EU) 2026/1778
4. Commission Implementing Decision (EU) 2026/1736 of 14 July 2026 on harmonised standards for Digital Product Passports.
   This Decision publishes the references to the first six harmonised European standards supporting the technical DPP framework, including standards covering data exchange protocols, unique identifiers, data carriers, data storage, APIs and system interoperability.
   EUR-Lex: Commission Implementing Decision (EU) 2026/1736
5. Regulation (EU) 2023/1542 of the European Parliament and of the Council concerning batteries and waste batteries.
   Article 77 establishes the battery passport requirement from 18 February 2027 for LMT batteries, industrial batteries with a capacity greater than 2 kWh and electric vehicle batteries.
   EUR-Lex: Regulation (EU) 2023/1542
6. Regulation (EU) 2024/3110 of the European Parliament and of the Council laying down harmonised rules for the marketing of construction products.
   The Regulation establishes the framework for the construction Digital Product Passport system and requires compatibility and interoperability with the DPP established under Regulation (EU) 2024/1781.
   EUR-Lex: Regulation (EU) 2024/3110
7. European Commission, Ecodesign for Sustainable Products and Energy Labelling Working Plan 2025-2030.
   The Working Plan identifies priority product groups for the first ESPR measures, including textiles/apparel, furniture, tyres, iron and steel, aluminium and other product categories, and provides indicative timelines for future product-specific measures.
   European Commission

Digital Product Passport requirements are developing progressively and differ by product category. Businesses should verify the latest applicable delegated acts, implementing measures and sector-specific EU legislation before implementing a DPP.