The Digital Product Passport Registry Is Now Operational: What It Means for Your Company

On 20 July 2026, the European Commission opened access to the Digital Product Passport Registry. It is not a statement of intent or a working plan: it is a real platform, currently available at registry.product-passport.ec.europa.eu, managed by the Directorate-General for Internal Market, Industry, Entrepreneurship and SMEs (DG GROW).

We have spent months talking about the DPP as something that is “coming”. From now on, it is already here.

Key Concepts About the Digital Product Passport Registry

DPP Registry

The European Commission’s central platform where verified economic operators register their digital product passports. It does not store the complete passport data: it only stores the unique identifiers of each product and the links to where that data is hosted. Access is free of charge.

Qualified Electronic Signature (QES)

The digital equivalent of the handwritten signature of a natural person, with the same legal value throughout the European Union. It is required by the DPP Registry when the person registering is a natural person acting as an economic operator in their own name, for example, a self-employed importer.

What the Digital Product Passport Registry Is

The Digital Product Passport Registry is the central infrastructure built by the European Commission to manage the digital product passports required by the Ecodesign for Sustainable Products Regulation (EU) 2024/1781 (ESPR).

It is important to clarify from the outset what it is and what it is not, because there is considerable confusion within the sector.

The Registry does not store all the passport data. It acts as an authorised index at European Union level: it contains the unique product identifiers (UPIs) and the links to where the complete DPP data is hosted. The passport data itself remains under the control of the economic operator or the service provider designated by that operator.

In other words: the Registry is the directory. The DPP is the record.

This distinction matters because it also determines where responsibility lies. The economic operator is responsible for creating and maintaining the data and for its accuracy throughout the product’s lifecycle.

Who Can Register DPPs: The Verification Requirement

The first condition established by Regulation (EU) 2024/1781 is clear: only verified economic operators can create and manage digital product passports.

Within the meaning of this Regulation, an economic operator includes the manufacturer, authorised representative, importer, distributor, dealer and fulfilment service provider. In practice, any company that places a product on the European market falls into this category.

To become verified, the organisation must prove its identity and its right to represent the entity being registered. This is where the element that many companies did not expect comes into play: the DPP certificate.

The Qualified Electronic Seal: The Requirement That Is Not Optional

When the verification process begins in the Registry, the European Commission generates a PDF declaration sealed with its own institutional seal. This declaration contains the details of the organisation seeking registration.

What happens next is decisive.

This document must be digitally countersigned or countersealed outside the system, and the instrument required depends on the type of entity:

• If the organisation is a legal person (a company or legally incorporated entity), the document must be sealed using a qualified electronic seal (QSeal) issued by a qualified trust service provider (QTSP).
• If the operator is a natural person acting as a sole trader, the document must be signed using a qualified electronic signature (QES) also issued by a QTSP.

This is not a best-practice recommendation. It is a technical requirement of the system: if the seal or signature does not reach the qualified level under the eIDAS Regulation, the verification fails and the organisation cannot access the Registry.

The DPP user guide published by DG GROW states it in these exact terms: “A QTSP is an accredited and authorised organisation that can issue qualified certificates. Signatures created with its certificates meet higher legal requirements.”

Why the Qualified Level Is the Only One That Works

There may be a temptation to resolve this using a conventional digital seal, an advanced signature or a server certificate already obtained for other purposes. The Registry system does not accept them.

The errors returned by the platform when the seal does not meet the requirements are very explicit:

• “The organisation’s seal does not reach the required qualified electronic seal (QSeal) level. Legal persons must use a qualified electronic seal.”
• “The certificate’s qualification level could not be established because it does not contain the necessary eIDAS attributes. Please contact your QTSP.”
• “The organisation’s signature or seal does not comply with the required PAdES Baseline format.”

In all these cases, the system rejects the application. The organisation is not verified. Without verification, it cannot register any DPP.

The difference between a qualified seal and a non-qualified seal is not only technical: it is legal. A qualified electronic seal under eIDAS benefits from a legal presumption of data integrity and accuracy of origin. No other type of seal provides this guarantee before a market surveillance authority.

What This Means for Companies in Practice

The Registry has opened with batteries as the first product group enabled for registration, in line with the mandatory battery passport scheduled for February 2027 under Regulation (EU) 2023/1542. The rollout to other product groups (textiles, steel, aluminium, furniture, construction products and more) will take place as the ESPR delegated acts are adopted.

However, the requirement for accessing the Registry, the qualified electronic seal, is the same for every sector. It will not change depending on the type of product. It is a condition for accessing the infrastructure, not a sector-specific requirement.

This means that companies wishing to be ready when the requirement becomes mandatory for their product category must address this issue now. Not in 2028. Not when the delegated act for their sector is adopted.

Obtaining a qualified electronic seal certificate involves a process of verifying the entity’s identity, checking its registration details and confirming legal representation. It is not something that can be completed through an online form in ten minutes.

What a QTSP Is and Why Inclusion in the Trusted List Matters

A qualified trust service provider, or QTSP, is an organisation supervised by the competent authority of a Member State and formally recognised in the European Trusted List under the eIDAS framework.

This status is not merely cosmetic. The European Trusted List, available at eidas.ec.europa.eu/efda/trust-services/browse/eidas/tls, contains the QTSPs from all Member States and the European Economic Area. A seal issued by a QTSP included in that list is automatically recognised as qualified in every Member State. A seal issued outside that list is not.

The DPP Registry validates certificates against that list. If the certificate used does not appear as qualified, the verification fails.v

Frequently Asked Questions (FAQ) About the DPP Registry

The Time to Prepare Is Now

For years, we have developed qualified trust services in accordance with the eIDAS Regulation. The DPP electronic seals for entities that we issue allow legal persons to prove their digital identity with the level of assurance required by the European market and, now, by the Digital Product Passport Registry.

If your company needs to register DPPs, the first step is to obtain this seal. That is what we are here for.

Do you have questions about the type of certificate your company needs or how the process for obtaining it works? Contact us and we will explain it to you.