Updated 4 August 2026: In response to our inquiry, the European Commission's DPP Help Desk named two dates that were still open in July. The semantic catalogue and the registry APIs are planned for Q4 2026, and only then will battery passport registration become technically possible. The rules for service providers registering on behalf of manufacturers will follow in a separate legal act, which the Commission expects around Q2 2027. Our article having your battery passport registered explains what that means in practice.
The short version: In July 2026 the EU set three milestones for the digital product passport. The central DPP registry, including a test environment, has been online since 20 July, the new Implementing Regulation (EU) 2026/1778 governs registration from 6 August, and six standards, including EN 18222, are now officially recognized. For battery manufacturers the deadline itself does not change: the passport obligation still starts on 18 February 2027. But the road there is now much clearer.
What happened in July 2026
Three dates within one week:
- 15 July: The EU officially recognizes six standards for the digital product passport, including EN 18222 for the interfaces (API) (Decision (EU) 2026/1736). The presumption of conformity it grants covers only the requirements of Articles 10 and 11 of the ESPR (Regulation (EU) 2024/1781), not the battery passport under Article 77 of the Battery Regulation. For battery manufacturers the standards are a recognized technical basis, not a proof of compliance.
- 17 July: Implementing Regulation (EU) 2026/1778 is published in the Official Journal. For the first time it sets out, in binding form, how the central DPP registry is structured and how registration works. It applies from 6 August 2026.
- 20 July: The registry goes online, together with a test environment where companies can practice the process safely.
We read all three sources in the original and walked through the registry ourselves with our own test account. This article summarizes what is actually in there, and what is not.
The registry is live: what it does and does not do
The most important point first: the registry is a directory, not a data store. It stores the unique product identifier (UPI), a reference to the passport and a small set of administrative data. The actual passport contents, meaning all battery, sustainability and compliance data, stay with the manufacturer or its software provider. The Commission's official user guide says so in as many words.
Three things stand out when you walk through the test environment:
- Access runs through an EU Login account; for the test environment you create a separate test account.
- The passport registration menu stays locked until your organization has been verified. The order is fixed: verify the company first, then register.
- Battery passports cannot be registered at all yet. The guide states clearly that the semantic catalogue for the battery product group has not yet been defined. The feature is coming, it simply has not been switched on.
So anyone hoping to “register quickly” today cannot, regardless of the provider. That is not bad news: it means time to build a clean data foundation before the real work starts.
The new registration regulation in plain language
Implementing Regulation (EU) 2026/1778 answers the questions that were open until now:
- Who may register? Only a verified economic operator. Article 78(e) of the Battery Regulation requires only that the battery passport stays available even when the responsible economic operator ceases to exist. Verification depends on the legal form: a legal person proves identity and establishment with a qualified electronic seal supported by a qualified certificate from a qualified trust service provider; the managing director's personal signature does not do it. Only a sole trader as a natural person identifies through a qualified electronic signature, or alternatively an electronic identification means at assurance level “high”. Verification is valid for three years at most, after which it is repeated.
- What is registered? Essentially the unique product identifier, a web address in a standardized format of up to 2000 characters. Batteries are registered at the level of the individual item.
- How is it registered? Either through the web interface or through an interface for automated submission, individually or in batches. Important for batches: if a single passport is faulty, the entire submission is rejected.
- May service providers take this over? In principle yes: the regulation expressly allows a third party to register on behalf of the manufacturer, provided that party is verified itself, and responsibility stays with the manufacturer. In practice the basis for this is still missing. On 4 August 2026 the European Commission confirmed to us that there is neither a list of verified service providers nor a procedure to be recognized as one; the requirements will only come with a separate legal act. So do not rely on a provider that claims this role today.
- What proof is there? On request, an official proof of registration as a secured document, available for 90 days and regenerable at any time.
One question is still open: ESPR Art. 10(4) requires the economic operator to make a back-up copy of the passport available through a passport service provider. That obligation belongs to the ESPR passport regime. Whether it also covers the battery passport under Art. 77 of the Battery Regulation is unsettled, because the ESPR added only the registry upload to that article (Art. 77(10)). Plan for a back-up copy as a precaution, but do not treat it as a proven duty for battery manufacturers.
Six recognized standards: what EN 18222 brings
Since 15 July, six product passport standards have been listed in the Official Journal, including EN 18222 for the interfaces (API) between passport systems. The practical effect is simple: whoever builds their system to these standards is automatically considered compliant on the points they cover. Instead of proving every technical requirement individually, you point to the standard.
Honesty still matters: there is no official seal or certificate for these standards. Claims like “certified to EN 18222” would be misleading, because nobody issues such a certificate. Serious providers state that their systems are built to the standards, and can back that up in detail.
The six standards in detail
Implementing Decision (EU) 2026/1736 of 14 July 2026 lists the standards with their titles. If you want to know which one matters to you, here they are at a glance:
- EN 18216:2026 Digital product passport, protocols for data exchange
- 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 data persistence
- EN 18222:2026 Digital product passport, application programming interfaces (APIs) for lifecycle management and searchability of the product passport
- EN 18223:2026 Digital product passport, system interoperability
The gap in the numbering is worth noting: EN 18217 and EN 18218 are missing from the list. The series is therefore not fully recognized, and anyone relying on it should name the number rather than the series.
Which products the registry actually covers
A common misconception is that the registry now serves all products. In fact Article 13 ESPR ties the registration duty to the delegated acts per product group. Only once such an act covers a product group does the duty arise, and Article 4(4) generally allows at least 18 months between entry into force and application.
One exception is written into the text: under Article 13(1) the registry stores “the unique identifiers for batteries referred to in Article 77(3) of Regulation (EU) 2023/1542”. The battery passport is named explicitly, without needing an ESPR act of its own.
Which groups those are is set out in the Ecodesign Working Plan 2025 to 2030, which the Commission presented on 16 April 2025 (COM(2025) 187 final). Among intermediate products, iron and steel come first with a delegated act due in 2026, followed by aluminium in 2027. Among final products, textiles and clothing and tyres are scheduled for 2027, furniture for 2028 and mattresses for 2029. Two horizontal requirements cut across the groups: repairability including a repairability score in 2027, and recycled content plus recyclability of electrical and electronic equipment in 2029. Sixteen energy-related products carried over from the earlier working plan, among them dishwashers, washing machines and refrigerating appliances, follow between 2026 and the end of 2030.
Two things follow. First, anyone making steel, textiles or tyres today has a concrete date ahead, not a statement of intent. Second, for anything missing from that list there is no passport date yet, whatever a vendor may claim. The working plan sets the order, not the obligation; a group becomes binding only with its own delegated act and the lead time from Article 4(4).
Customs checks along the way
The point most often missing from discussions: the registry hangs on import clearance. Article 15 ESPR requires anyone declaring a covered product for release for free circulation to provide the customs authorities with the unique registration identifier under Article 13(5). And customs may only release a product once they have at least verified that the registration identifier and the commodity code match the data stored in the registry. That duty applies from the date the registry is operational.
For importers that means registration is not a formality you can catch up on later. Without a matching identifier the goods stay at the border.
What battery manufacturers should do now
The obligation starts on 18 February 2027. A sensible order:
- 1. Build your data foundation: In practice the passport obligation rarely fails on technology, it fails on missing data (carbon footprint, materials, supply chain). Start early and the hardest part is behind you. Our checklist for 2027 walks through every point.
- 2. Look at the test environment: Create a free EU Login test account and click through the organization verification flow once. No surprises later at the seal step.
- 3. Sort out the seal question: As a legal person, your company needs a qualified electronic seal for verification; only sole traders as natural persons get by with a qualified signature. If you do not have one yet, plan the purchase from a trust service provider.
- 4. Assign responsibility: Decide whether you handle registration yourself or hand it to your software provider. Both are allowed, responsibility stays in-house.
- 5. Watch for the go-live: As soon as the EU switches on the battery catalog, registration can start. We track this continuously and keep our battery passport overview up to date.
How the registry works in general and how it differs from the passport is covered in depth in our article on the EU battery passport registry; the technical basis of the passport data is explained in DIN SPEC 99100 explained.
The legal deadline, and what registration is not
The 20 July launch was not an arbitrary date. Article 13(1) of the Ecodesign Regulation gives the Commission a hard deadline: “By 19 July 2026, the Commission shall set up a digital registry … storing at least the unique product identifiers in a secure manner.” The same paragraph says what else belongs there: for products to be released for free circulation, the commodity code, and expressly the individual identifiers for batteries under Article 77(3) of the Battery Regulation. The launch on 20 July therefore came a day past the deadline.
More important than the date is a clarification: registration is not proof of conformity. The registry stores identifiers, not test results. Filing your identifier there means neither that you have been through conformity assessment nor that anyone confirmed the content of your passport. That check stays with the notified bodies and market surveillance, and the economic operator remains responsible under Article 77(4) for the entries being correct, complete and up to date. Advertising “registered in the EU registry” therefore promises less than it sounds like.
The framework behind this is eIDAS: Regulation (EU) 910/2014 defines what a qualified trust service provider is and what effect a qualified seal has. For legal persons the seal is the right instrument; the qualified signature of a natural person fits only the sole trader. In practice: you need a certificate issued to the organization by a provider on the national trusted list. Obtaining it takes days to weeks depending on the provider, because the company's identity is checked.
Where to read up and ask today
The Commission has set up a dedicated digital product passport page alongside the registry. It holds the documents you need for preparation, free of charge: the “User Guide for Economic Operators” for the DPP Registry, from July 2026 and, particularly relevant for batteries, the paper “data point by category” for the Digital Batteries Passport, from August 2026. The implementing decision on the six DPP standards sits there too.
The registry launched together with a test environment. If you want to check whether your identifiers and your data format get through, you can do that there before it counts. For questions, support and feedback the Commission gives the address GROW-DIGITAL-PRODUCT-PASSPORT@ec.europa.eu.
What the page does not list is a freely accessible semantic repository. The semantic catalogue is announced but not yet published. So if you fix a data model today, build it so that field names can be mapped later, rather than waiting for one that is still to come.
Which identifier to choose, and how it reaches the registry
The Regulation prescribes no identifier system. Article 77(3) of the Battery Regulation requires the QR code and the unique identifier to comply with ISO/IEC standards 15459-1 to -6 or equivalent standards. The term GS1 does not appear once in the Ecodesign Regulation. So choosing GS1 Digital Link means choosing one possible route, not the prescribed one.
For the route into the registry, what counts is what Article 13(1) of the Ecodesign Regulation stores there: at least the unique product identifiers, for products destined for free circulation also the commodity code, and expressly the individual identifiers for batteries under Article 77(3). So your identifier has to be storable in that form, whatever system it comes from.
The practical advantage of a GS1 Digital Link identifier lies elsewhere: it is built as a web address at the same time, and the same code can later be reused at the retail checkout. If you already run GTIN and serial number, that saves a second code on the packaging. If you hold no GS1 identifiers, you do not need to apply for them for the battery passport.
Frequently asked questions
Do I have to register my batteries already?
No, and currently you could not even if you wanted to: battery registration is not yet enabled in the registry because the semantic catalogue is missing. The passport obligation itself starts on 18 February 2027.
Will the EU store all my battery data?
No. The registry only stores the identifier and the reference to the passport. The passport data stays with you or your software provider, and you keep control over it.
Can my software provider handle the registration for me?
Legally it is foreseen, practically it is not possible yet. The Implementing Regulation allows registration on behalf of a manufacturer if the provider is verified. However, on 4 August 2026 the European Commission told us that the list of verified service providers and the recognition procedure do not exist yet, and that the rules will only arrive with a later legal act. Legal responsibility for correctness always stays with the manufacturer.
What does the registry cost?
According to the official user guide, no fee is planned for the registration itself. Costs arise for the qualified seal from the trust service provider and for building the passport data.
Last updated: 22 July 2026. All information to the best of our knowledge based on the official sources (Decision (EU) 2026/1736, Implementing Regulation (EU) 2026/1778, ESPR (EU) 2024/1781, Battery Regulation (EU) 2023/1542) and our own walkthrough of the registry test environment; not legal advice.
