The European Commission's digital product passport (DPP) registry went live on 20 July 2026, together with a test environment. The system does not hold the passport itself; it holds the unique identifiers that lead to the passport and the commodity code for customs. The passport data stays with the manufacturer or with a service provider it authorises. So the first task for an exporter is to set up correctly the identifier to be assigned to the product and the code that will carry it.
What does the registry hold, and what does it not?
The legal basis of the registry is Article 13 of the ESPR, and its operation is set by Commission Implementing Regulation (EU) 2026/1778 of 16 July 2026. Under Article 8 of that regulation, the system stores:
- The product's unique identifiers.
- The commodity code for products released for free circulation.
- A reference to the service provider hosting the passport.
- Details of who made the registration, a timestamp and integrity information.
The content of the passport, such as composition, compliance documents or instructions for use, is not held in the central system. When registration is complete, the system generates a persistent unique registration identifier and issues a registration certificate bearing an electronic seal. The ESPR states clearly that this identifier is not proof of compliance.
On the customs side, the importer declares this registration identifier in the customs declaration. Customs then checks the identifier and commodity code against the registry. Full connection with the customs single window will be established within four years of the implementing regulation's entry into force.
Who registers?
The economic operator placing the product on the EU market registers; for a product exported from Türkiye, this is usually the importer in the EU. Registration must be made before the product is placed on the market. The implementing regulation sets a few more rules:
- Verified operator: Only operators verified with a qualified electronic signature, seal or attestation can register. Verification is valid for a maximum of three years.
- Interface or API: Registration can be made through the web interface or in bulk through an API.
- Level of granularity: Registration is made at model, batch or item level, whichever the relevant product act requires. Where more than one act applies, the most detailed level is chosen.
- Automated checks: The system checks mandatory data, the level of granularity, the commodity code and the back-up copy link.
- National administrators: Each Member State appoints a national administrator by 18 February 2027.
The first mandatory use of the registry starts with certain battery types on 18 February 2027. We explain the details in our battery passport article.
What should the unique product identifier look like?
The ESPR defines the unique product identifier as a string of characters that identifies a product uniquely and also provides a web link to the passport. Annex III of the regulation requires the identifier and the data carrier to comply with six parts of the ISO/IEC 15459 series. ISO/IEC 15459 is the standard that governs issuing agencies for identifiers and the global uniqueness of numbers; GS1 is one of the issuing agencies under this standard.
Three properties of the identifier stand out:
- It must be persistent. It must not change over the product's life and must not be assigned to another product.
- It must match the level of granularity. Model, batch or item; whichever is required.
- At item level, it must link to the higher records. Under the implementing regulation, an item-level passport is linked to the identifiers of the batch and the model.
In GS1's approach, the GTIN is used for the model, the GTIN with a batch number for the batch, and the GTIN with a serial number for the individual item. In our GTIN article we explain how the number is obtained in Türkiye. A separate Commission act governing the lifecycle of identifiers has not been adopted yet; the Commission's presentation puts it in the second quarter of 2027.
Which standards are now in force?
JTC 24, the joint technical committee of CEN and CENELEC, has published eight European standards for the digital product passport. Six of them were published in the Official Journal of the EU as harmonised standards on 15 July 2026 by Commission Implementing Decision (EU) 2026/1736:
| Standard | Subject |
|---|---|
| EN 18216:2026 | Data exchange protocols |
| EN 18219:2026 | Unique identifiers |
| EN 18220:2026 | Data carriers |
| EN 18221:2026 | Data storage, archiving and persistence |
| EN 18222:2026 | APIs for passport lifecycle management and searchability |
| EN 18223:2026 | System interoperability |
A passport that complies with these standards is presumed to conform with Articles 10 and 11 of the ESPR to the extent they cover. For the standards on access rights and security (EN 18239) and on data authentication and integrity (EN 18246), published in September 2026, publication of their references in the Official Journal is planned for November 2026.
Where does the data carrier go?
Under the ESPR, the data carrier can be a linear barcode, a two-dimensional code or another automatic identification technology that can be read by a device. The carrier must be physically present on the product itself, its packaging or the accompanying documents. Which carrier goes where will be set by the act for each product group.
The operator must also provide dealers and online marketplaces, on request, with a digital copy of the carrier or the identifier within five working days, free of charge. Access to the passport in marketplace listings is expected to be provided this way.
What do the back-up copy and the service provider mean?
The passport is not stored in a central system but with the responsible operator or with a digital product passport service provider it authorises. The ESPR sets two rules:
- A back-up copy is mandatory: When placing the product on the market, the operator must make a back-up copy of the passport available through an independent service provider (Article 10(4)). The passport also contains a reference to this provider.
- The passport must be persistent: The passport must remain accessible even if the operator goes bankrupt, is liquidated or withdraws from the EU (Article 11).
Service providers cannot sell the data or use it outside the service unless agreed with the operator. The act that will set requirements for service providers and a possible certification scheme has not been adopted yet. The Commission expects it in the second or third quarter of 2027. The Ministry of Trade is requesting that Turkish service providers receive the same treatment as EU providers within the framework of the Customs Union.
What comes next on the timeline?
- 18 February 2027: Passport and registration obligations for certain batteries. Deadline for appointing national administrators.
- First half of 2027: Acts on service providers, the lifecycle of identifiers and digital credentials.
- 2028: Passport obligations for iron and steel, construction products and packaging, according to the Commission's timeline.
- 2029: Apparel, tyres, aluminium, information and communication technology products and detergents.
- 1 August 2030: Toys.
The 2028 and 2029 dates are indicative and depend on the adoption of the relevant acts. We cover the situation in apparel separately in our apparel passport article.
Does registration show that a product is genuine?
No. Article 11 of the ESPR requires passport data to be accurate, reliable and intact; this requirement protects the record. The QR code on the product, however, can be copied and printed on another product. The registry alone does not prove that the product in your hands is the product on record. We cover this distinction in our article on tracking and verification.
Where does Spectrace fit in this preparation?
Tagvex numbers products at batch or unit level with copy-resistant codes, fits the code into the existing label layout and records every change of hands; records can be passed to ERP and warehouse systems through an API. This is the identifier and data preparation layer. It does not replace DPP Registry registration, a passport service provider or GS1 numbers.
Sources
- EUR-Lex, Regulation (EU) 2024/1781 (ESPR)
- EUR-Lex, Commission Implementing Regulation (EU) 2026/1778
- EUR-Lex, Commission Implementing Decision (EU) 2026/1736
- European Commission, Digital product passport registry now live, 20 July 2026
- European Commission, DPP registry
- CEN-CENELEC JTC 24, published standards
- Ministry of Trade of Türkiye, Statement on the launch of the DPP registry (Turkish), 2026
