Eleven days ago we wrote about the draft implementing regulation for the EU's Digital Product Passport registry and ended on a deliberate note: our submission format would not be called final until the adopted text was published in the Official Journal. That gate has now opened.
On 16 July the Commission adopted Implementing Regulation (EU) 2026/1778, laying down the implementation arrangements for the DPP registry established under Article 13 of the ESPR. It was published in the Official Journal on 17 July and enters into force on 6 August. Two days earlier, Implementing Decision (EU) 2026/1736 cited the six horizontal DPP standards — EN 18216, EN 18219, EN 18220, EN 18221, EN 18222 and EN 18223 — in the Official Journal, which means conformity with those standards now carries a formal presumption of conformity with the ESPR's passport requirements. And today, 20 July, the Commission's registry page confirms the registry itself is operational, together with a testing environment and user guidelines.
A year of "details pending" ended in five days. Here is what the adopted text confirms, the one point where it differs from what we wrote about the draft, and what none of it changes.
What the adopted text confirms
Submission is machine-to-machine, as expected. Article 8 of the regulation provides for registration through a secure user interface or through an API. At any volume, the API is the route that matters, and the registry validates each submission automatically on arrival: semantic conformity of the passport data against the applicable acts, the granularity level (model, batch or item), the commodity code, and the link to the passport's backup host.
Proof of registration works the way the draft described. A registered passport can generate a proof at any time — a secure document guaranteed by the Commission's own qualified electronic seal, carrying the unique product identifier, the responsible operator's verified identity, a timestamp and a hash of the passport version. Each generated proof remains available for 90 calendar days. This is the artefact an importer or authorised representative will actually present to show the obligation is met.
The registry keeps a public list of verified DPP service providers. Article 3 names it as a component of the registry itself — worth knowing when you assess any provider, including us.
The one point that changed: operator verification
This is the part of the adopted text that differs in emphasis from the draft as we read it, and honesty requires saying so plainly.
To register passports, an economic operator must first become a verified economic operator. For a legal person, that means evidencing identity and establishment with a qualified electronic seal under eIDAS — or a qualified electronic attestation of attributes issued under Union law. Verification holds until the credential expires, and for no more than three years, after which it must be repeated.
The regulation does allow delegation: a verified operator may authorise a third party — a passport platform, for instance — to perform registration actions on its behalf, provided that third party has itself been verified. But delegation covers the actions, not the identity. Your provider can carry the API integration, the submission format, the proof handling and its own verification as the acting party. What it cannot carry is your verification as the responsible operator. That step is yours, it is a one-time process repeated at most every three years, and it is considerably easier to complete in the coming months than in the weeks before February 2027.
In our draft-regulation piece we said the e-seal integration was plumbing your provider carries. For the submission machinery, that holds. For your status as a verified operator, the adopted text is clear that the credential is yours. That distinction is exactly why we gate on adopted text rather than drafts — and why every field and rule in our registry format carries a recorded source, so reconciling draft against final is a checking exercise, not a rebuild.
What did not change
Nothing became mandatory for economic operators today. The registry going operational is infrastructure: the Commission meeting its own Article 13 obligation. The date that binds you is the one that has never moved — from 18 February 2027, each LMT battery, each EV battery and each industrial battery above 2 kWh placed on the EU market needs a registered passport under Article 77 of the Battery Regulation.
What today changes is the quality of the time between now and then. The registry exists, the rules governing it are law, the standards carry presumption of conformity, and a testing environment is open. Every unknown an operator could reasonably have cited as a reason to wait has now been published.
If you are an importer, an authorised representative, or a manufacturer issuing your own passports, the practical sequence is short: confirm who your verified operator is, plan the one-time verification, and make sure whoever handles your submissions is aligned to the adopted texts — by number, not by vibe. Our registry readiness page tracks exactly what the platform aligns to and the status of each source: where the registry now stands.
What changed in EU battery and product-passport regulation, what it means for operators, and the dates ahead.
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