Verifying as an Economic Operator: the qualified seal, step by step
Before any Digital Product Passport can be registered, the economic operator behind it must be verified in the Commission's DPP Registry — and verification is the one step no platform can perform for you. This page describes the process as it actually works, based on our own completed verification in the registry's acceptance environment in July 2026. It is a factual walk-through, not legal advice, and the registry is an evolving system: check the date stamp below.
What the regulation requires
Under Implementing Regulation (EU) 2026/1778, Article 4(2), a legal person verifies by evidencing its identity — and, where applicable, its establishment — by means of a qualified electronic seal supported by a qualified certificate for electronic seal, issued by a qualified trust service provider (QTSP) under Regulation (EU) No 910/2014 (eIDAS). A qualified electronic attestation of attributes is the alternative route. Verified status remains valid until the underlying credential expires, up to a maximum of three years. Operators already verified in another integrated Union system with an equivalent process — the regulation names EPREL as an example — should not need to verify twice.
Seal, not signature
The single most common procurement mistake: a qualified electronic seal is an organisational credential issued to the legal entity. It is not the same product as a director's personal qualified electronic signature (QES). If a trust service provider quotes a personal signing certificate, that is the wrong product for this process. QTSPs are listed in the EU Trusted List; any qualified provider's seal is acceptable — the registry does not favour particular providers, and neither do we.
The identifier, character for character
The seal certificate carries the organisation identifier in a standardised composite form defined by ETSI EN 319 412-1: a three-letter scheme code, a two-letter country code, a hyphen, and the registration number — for example, a scheme of NTR (national trade register) followed by the country and company number. The registry compares this value against the identifier stored on your organisation record as an exact character string. If your registry profile holds a bare company number while the certificate carries the composite form, verification fails — and the rejection message does not identify which field disagreed. Before sealing anything, open your certificate, read the organizationIdentifier attribute, and make your registry organisation record match it exactly.
The flow
- 1
Enrol your organisation in the registry and complete the organisation record — legal name, address, country of registration, identifier type and value.
- 2
Generate the Commission's declaration document from within the registry.
- 3
Apply the qualified electronic seal to the declaration — sealed by the legal representative, using the organisation's seal certificate.
- 4
Upload the sealed declaration. The registry validates the seal and compares the certificate's organisation identifier against your record.
- 5
On success, your account becomes the verified administrator for the organisation and passport registration functions unlock.
Failure modes we hit so you don't have to
- Identifier mismatch: bare registration number in the profile vs the ETSI composite on the certificate — the cause of four consecutive rejections in our own run. Exact-string matching applies.
- Wrong credential type: a personal qualified signature in place of an organisational qualified seal.
- Seal validity is necessary but not sufficient: our sealed declaration validated as fully qualified (QESeal, total-passed) in the Commission's own DSS validator while still being rejected on the identifier comparison — a valid seal does not guarantee a passing verification.
- Passport URL hygiene matters later: the registry fetches unique product identifier URLs at registration time, and its documented failure causes include redirect chains and protocol downgrades. Sort this before your first registration attempt, not after.
Current state
Verified against the live system: 23 July 2026
Operator verification is fully operational in the registry's acceptance environment. Registration of battery passports is not yet possible for any operator: the Commission's User Guide for Economic Operators states that the semantic catalogue for the product group has not yet been defined. The first binding registration deadline is 18 February 2027 for LMT, EV and industrial batteries above 2 kWh. Verifying now, well ahead of that date, is the step that cannot be compressed later.
Verification is yours; the machinery around it is delegable. Formatting passports, generating registry batch files, keeping identifier URLs clean, and submitting when the registry opens for your product group — that is what a platform absorbs. We publish the live status of every part of the registry, verified from inside it, on our registry status page.
Where the registry stands now