Implementing Regulation on the Product Passport Register

On 16 July 2026, the European Commission adopted Implementing Regulation (EU) 2026/1778 on the Digital Product Passport Register (DPPRR). With the DPPRR and the corresponding Product Passport Register, the Commission is taking significant steps towards the introduction of the Digital Product Passport (DPP).

What is the digital product passport?

The General DPP was introduced by the Ecodesign Regulation (EU) 2024/1781 (Ecodesign Regulation). In the future, the DPP is intended to provide easily accessible product information relating to key product characteristics (Recital 32 of the Ecodesign Regulation). This is intended to make it considerably easier for economic operators and the authorities to access this information. At the same time, it is intended to facilitate the traceability of products within the supply chain (Article 9(3) of the Ecodesign Regulation).

What is the Digital Product Passport Register?

Under Article 13 of the Ecodesign Regulation, the Commission is required to establish a product passport register. It has now laid down the implementing rules for its operation in the DPPRR.

The Product Passport Register provides the basic IT infrastructure for the future mandatory registration of digital product passports. Not all the information that will ultimately be provided in a particular product’s DPP is stored in the register. Instead, the Product Passport Register records core data associated with the product and its DPP. This includes, for example, unique identifiers and commodity codes assigned to the product (Article 8(9) of the DPPRR). The specific data involved may also depend, in each individual case, on the legal act requiring registration.

In order to register a DPP in the Product Passport Register, you must register for the register and provide qualified identification (Art. 4 DPPRR).

Which rules does the new implementing regulation on the product passport register set out?

The DPPRR provides the legal basis for the technical design of the product passport register. To this end, it sets out the following in particular:

• The technical design of the product passport register
• Registration requirements
• Management, modification and transfer of registered DPPs
• Access rights and authorisation arrangements for public authorities, economic operators and customs authorities
• Data processing requirements

For which products will DPPs need to be registered in the Product Passport Register?

The registration requirement applies to products for which the law stipulates that a DPP must be in place and registered in the Product Passport Register before they are placed on the market or put into service (Article 1(1)(f) of the DPPR Regulation). At present, the range of products to which this requirement applies is still limited; however, the registration requirements are to be gradually extended.

At present, the law requires the following products to have a DPP and to be registered in the Product Passport Register:

• From 18 February 2027: The battery passport for LMT batteries, industrial batteries with a capacity of more than 2 kWh and electric vehicle batteries (Article 77(1), (10) of the Battery Regulation (EU) 2023/1542).
• From 23 September 2029: Detergents and surfactants (Articles 21 et seq., 24(1), 37 of the Detergents and Surfactants Regulation (EU) 2026/405)
• From 1 August 2030: Toys (Articles 19 et seq., 22(1) and 59 of the Toys Regulation (EU) 2025/2509)

DPP regulations and registration requirements have been announced for the following products:

• Packaging falling within the scope of the Packaging Regulation (EU) 2025/40
• Construction products in accordance with Article 75 et seq. and Article 79(2) of the Construction Products Regulation (EU) 2024/3110
• Textiles
• Furniture
• Tyres
• Mattresses
• Energy-related products
• ICT products
• Iron and steel
• Aluminium

How can businesses prepare for registration obligations?

The Product Passport Register is already available online. The Commission is also providing a test environment where economic operators can test its functions and familiarise themselves with the register. You can access the Product Passport Register and the test environment via the following link: Link.

In particular, economic operators that are required to register battery passports from 18 February 2027 should familiarize themselves with the Product Passport Register in good time.