The digital product passport is quickly becoming a new cost of doing business in the EU - and the rulebook for the registry that will power it has just landed. On 16 July 2026, the European Commission adopted Implementing Regulation (EU) 2026/1778, turning the legal framework of Regulation (EU) 2024/1781 into a concrete, working system: who gets access, how identities are verified, how data is stored and protected, and who carries the liability when something goes wrong.
Is your business in scope? A detailed look at the rules
If your company places products on the EU market, this regulation may already be relevant to you. It applies to any economic operator that places a product on the EU market or puts it into service where a digital product passport is required, and it names the current product categories in scope:
Products covered by delegated acts adopted under Article 4 of Regulation (EU) 2024/1781, the core ecodesign framework regulation.
Batteries covered by Article 77 of Regulation (EU) 2023/1542, the batteries and waste batteries regulation.
Construction products covered by Article 76 of Regulation (EU) 2024/3110.
Toys covered by Article 19 of Regulation (EU) 2025/2509.
Detergents and end-user surfactants covered by Article 21 of Regulation (EU) 2026/405.
A catch-all category: any other product for which Union legislation requires a digital product passport and registration in the registry established under Article 13 of Regulation (EU) 2024/1781 — a clear signal that the list of covered products will only keep growing.
Beyond product coverage, the Regulation also sets out a comprehensive governance framework for the operation of the registry itself. It establishes the rules for managing access to the registry and verifying the identities of economic operators and value-chain actors, while also defining the technical architecture underpinning the system, including the semantic repository, data-exchange model logs, and software release management processes. The framework covers the registration and storage of unique identifiers and commodity codes for products entering the EU under the customs procedure of “release for free circulation”, as well as the requirements for recording the appropriate digital product passport granularity level—whether at model, batch, or item level. In addition, it governs the management of passport statuses, the handling of traceability data across product groups and granularity levels, and the updating or deletion of registration data. The Regulation further addresses the processing of personal data, introduces measures to prevent, detect, and respond to improper or fraudulent use of the registry, provides for technical audits, and establishes requirements to ensure the ongoing availability and reliability of both the registry and the data it contains.
Importantly, this isn't just a manufacturer's problem: the rules extend across the entire value chain, governing how repairers, refurbishers, remanufacturers, and recyclers, alongside national authorities, customs authorities, and the Commission, each interact with the registry. Where other EU legislation — such as the rules on construction products, toys, or detergents — refers back to the Article 13 registry, these same implementation arrangements apply, without prejudice to any more specific rules in that sector-specific legislation.
Discover the highlights of the DPP registry
Verified or nothing. Only "verified economic operators" — companies or sole traders who've proven their identity via qualified e-signatures, e-seals, or high-assurance eID — can register or edit a DPP. Verification lasts up to 3 years before renewal.
Right granularity, every time. Passports must be registered at the model, batch, or item level — whatever the applicable law demands. No shortcuts.
Automatic checks. Once submitted, the Commission's system automatically verifies data structure, semantic conformity, and granularity — generating a unique registration ID on the spot.
Proof you can trust. Need evidence your product is properly registered? Generate a secure, digitally-sealed proof of registration, valid and downloadable for 90 days.
Built to last (but not forever). Registration data sticks around for 10 years by default, unless other EU law says otherwise. Full versioning and audit logging included.
Ownership can move. Selling your business or restructuring? DPPs can be transferred to another verified operator — no data limbo.
Free semantic repository. A shared library of data models and definitions (with public APIs) ensures every passport speaks the same language — accessible free of charge to all.
What passport-ready means in practice: A business-readiness view of the major compliance actions enabled by the EU DPP Registry
Why the DPP Registry rules matter for your business
This isn't just red tape — it's the EU building the digital backbone for a circular, transparent economy. Whether you make batteries, toys, or construction materials, the clock is ticking to get your compliance and IT teams ready for identity verification, data structuring, and registry integration.
Bottom line: the DPP Registry is no longer a concept on paper — it's operational infrastructure. Time to get your products "passport-ready."
Want a deep dive into what this means for your specific product category? Reach out — we're already mapping the compliance roadmap.
Contact us
Klaudia Meszaros-Musiol
Marvin Yabili