The answer in 40 seconds: No, nobody can register a battery passport with the EU today, not even a service provider. On 4 August 2026 the European Commission confirmed to us that the semantic catalogue and the registry APIs are planned for Q4 2026, and that the rules for service providers will only come with a separate legal act, which the Commission expects to be adopted around Q2 2027. The passport obligation itself remains 18 February 2027.
The short answer: nobody can do this today
The question comes up in almost every conversation: do I have to register my battery passports with the EU myself, or will my software provider handle it?
The honest answer in August 2026 is: neither, because it simply is not possible yet. The EU's central DPP registry has been online since 20 July 2026, but the battery product group is locked. The Commission's official user guide states plainly that the semantic catalogue for this product group has not yet been defined and that successful registration is therefore not currently possible.
If a provider promises you today that they already register your passports with the EU, that is not true. It is a useful first test of how carefully a provider reads its sources.
What the European Commission wrote to us on 4 August
Because there is a lot of guesswork on this point, we sent four questions to the Commission's DPP Help Desk on 22 July 2026: when will the API documentation arrive, how does registration on behalf of a manufacturer work technically, how does a company become a verified service provider, and when will battery registration be enabled?
The reply arrived on 4 August 2026. Four points matter for manufacturers:
- Catalogue and APIs: Q4 2026. The semantic catalogue and the registry APIs are planned for the fourth quarter of 2026, together with comprehensive technical documentation. Only after that can anyone register in an automated way.
- There is no list of verified service providers. And there is no procedure to be recognised as one. According to the Commission, neither is in place at this stage.
- The rules will come later. Requirements, criteria and permitted actions for service providers are to be set out in a delegated act, which the Commission expects to be adopted around the second quarter of 2027. In parallel it plans to roll out the corresponding registry functionality.
- The first passports are battery passports. They follow from the Batteries Regulation as of February 2027, and that has not changed.
This information comes from a Help Desk reply to our enquiry. It is not a legal act and not legal advice, but it is the most recent official statement on these dates that we are aware of.
The gap almost nobody talks about
One sentence from the reply deserves particular attention. The Commission points out a difference between the Batteries Regulation and the Ecodesign Regulation: the digital product passport service provider does not appear as a defined actor in the Batteries Regulation at all.
The term "digital product passport service provider" is defined in the Ecodesign Regulation (EU) 2024/1781, and the registration regulation (EU) 2026/1778 expressly allows a third party to register on behalf of a verified economic operator. The Batteries Regulation (EU) 2023/1542, which makes your passport mandatory from February 2027, does not know this role.
What does that mean in practice? It does not mean that working on behalf of a manufacturer is forbidden. It means the precise roles and rights of a service provider towards the manufacturer and the registry have not been written out yet and will only arrive with the upcoming legal acts. For you as a manufacturer the consequence is simple: responsibility for your passport stays with you, no matter who runs the technology. The registration regulation says as much, stating explicitly that the economic operator remains liable even when a third party registers on their behalf.
The timeline you can plan with
- 6 August 2026: Implementing Regulation (EU) 2026/1778 becomes applicable. It governs the framework, not the battery content.
- Q4 2026: Semantic catalogue and registry APIs, according to the Commission with full documentation. This is when technical integration becomes real.
- 18 February 2027: The battery passport becomes mandatory for the affected battery types. No passport, no placing on the market.
- Around Q2 2027: Expected adoption of the legal act on service providers, with the matching registry functionality to follow.
Note the order: the passport obligation comes before the service provider rules. Your company therefore has to be able to act on its own in February 2027 and cannot rely on someone else being officially allowed to register for you by then.
What you can usefully prepare now
Waiting does not mean doing nothing. These four steps are possible today and pay off later:
- 1. Build your data base. In practice the passport rarely fails on technology, it fails on missing data: material composition, supply chain, carbon figures, safety information. That is manual work with suppliers and takes months. Our battery passport overview lists what is required in detail. Start there, not with the interface.
- 2. Understand verification. Only a verified economic operator may register. For companies that means a qualified electronic seal; a personal signature by the managing director is expressly not enough. Verification is valid for at most three years and must then be repeated.
- 3. Do not buy the seal too early. A qualified seal costs between roughly 200 and 1,000 euros per year depending on provider and format. Important: the validity period starts at issuance, not at first use. Buying today burns months during which registration is blocked anyway. Instead, ask your provider now how long the application and identity check take, and time the purchase so the validity covers early 2027 onwards. Which providers are admissible at all is public information in the EU trusted list.
- 4. Assign responsibility. Decide internally who maintains the passport and who will trigger the later registration. Even if a service provider supplies the technology, you need a responsible person with access to your organisation's EU Login. If you are comparing tools, our pages on battery passport software and digital product passport software set out what such a system has to cover.
How the passport is structured and which other deadlines apply is covered in when the battery passport becomes mandatory. The structure of the registry itself is explained in the EU battery passport registry, and what changed in July 2026 is in the EU DPP registry is live.
Three questions to test any provider
Because the legal situation is unfinished, a lot is being promised right now. These three questions separate solid statements from marketing:
- "Do you already register my passports with the EU?" Any answer other than a clear no is wrong. Battery registration is locked.
- "Are you a verified DPP service provider?" Nobody can be one at the moment, because neither the list nor the procedure exists. A provider claiming this has not read the source.
- "Is your system certified?" There is no seal and no certificate for the battery passport, not even for the relevant standards. The honest formulation is that a system is built to the standards, with evidence in detail.
We hold ourselves to the same rule: with DPP Hero you can create, check, publish and export your battery passports today. We will build the connection to the EU registry once the Commission has published the interface, and not a day earlier, because until then nobody knows what it looks like. If you want to start on the data now, create a free account and build your first passport.
Frequently asked questions
Can my software provider register the battery passport for me?
Not today, because battery registration in the EU registry is locked. Legally, registration on behalf of a manufacturer is foreseen; practically, both the recognition of service providers and the technical interface are still missing. According to the Commission, both will come later.
When can I register my battery passports?
According to the European Commission's reply of 4 August 2026, the semantic catalogue and the APIs are planned for Q4 2026. The Commission does not give an exact date. The passport obligation itself starts on 18 February 2027.
Do I have to verify my company with the EU myself?
Yes. Verification is tied to your organisation and runs through a qualified electronic seal. A service provider can guide you through it, but cannot provide the proof on your behalf.
Is it worth buying the seal now?
Usually not. Validity starts at issuance, and months would pass unused before registration is even enabled. It is more sensible to ask your provider about processing times now and to time the purchase so that validity covers early 2027 onwards.
What happens if I have no passport on 18 February 2027?
Then the affected batteries may not be placed on the market. The obligation applies to the manufacturer or importer, not to the software provider.
Sources
- Batteries Regulation (EU) 2023/1542, Article 77 and Annex XIII govern the battery passport
- Implementing Regulation (EU) 2026/1778 on the registry, applicable from 6 August 2026
- The Commission's DPP registry with user guide and test environment
Status: 4 August 2026. Based on the official sources (Batteries Regulation (EU) 2023/1542, ESPR (EU) 2024/1781, Implementing Regulation (EU) 2026/1778, the Commission's registry user guide) and on a reply from the European Commission's DPP Help Desk of 4 August 2026 to our enquiry. Dates the Commission describes as planning are not a commitment. This is not legal advice.
