What the act is
Commission Implementing Regulation (EU) 2026/1778 of 16 July 2026 lays down the implementation arrangements for the digital product passport registry set up under Article 13 of the Ecodesign for Sustainable Products Regulation (ESPR), Regulation (EU) 2024/1781. It was published in the Official Journal on 17 July 2026 (OJ L, 2026/1778) and entered into force on the twentieth day after publication, 6 August 2026.
The registry itself opened on 20 July 2026, together with a testing environment, at registry.product-passport.ec.europa.eu. Our guide to the EU DPP Registry covers the architecture; this post covers the legal act that governs it.
Key details
- CELEX number: 32026R1778
- Adopted: 16 July 2026 (Brussels)
- Published: 17 July 2026, OJ L 2026/1778
- In force: 6 August 2026
- Full text: View on EUR-Lex
- Type: Implementing Regulation under Regulation (EU) 2024/1781
What it requires
The regulation sets the rules for access to the registry, verification of the economic operators who use it, the registration of passports and the data the registry stores. Its main points:
- Verified operators. Registration is made by a verified economic operator, through the registry's secure user interface or, once published, its API.
- Register before placing on the market. Each digital product passport is registered with its unique product identifier and the metadata the registry needs to find it; the passport data itself stays with the economic operator or its DPP service provider. The registry is a federated index, not a data store.
- Registration identifier. A successful registration produces a downloadable, secure electronic confirmation containing at least the unique product identifier, where relevant the commodity code, the name and identity of the verified operator responsible for the registration, and the date and time of registration.
- Authorities' access. Market surveillance and customs authorities query the registry to verify that a product's passport exists and is registered to the claimed operator.
- Review. The Commission must evaluate how the registry is working and, if appropriate, propose a revision.
What it means for businesses
Registration becomes mandatory product group by product group, as each passport obligation starts to apply. The first is the battery passport on 18 February 2027 under Regulation (EU) 2023/1542; the first ESPR product groups (iron and steel, then textiles, tyres and aluminium) follow from 2028, at least 18 months after their delegated acts are adopted. Until then, the registry's testing environment is where to rehearse.
In practice that means three things: assign a unique product identifier to every model or item that will need a passport, choose a hosting model whose passports can be registered through the registry's interface or API, and keep the registration identifier the registry returns with each passport's record.
How to prepare
- Read the full text on EUR-Lex, in particular the articles on verification of economic operators and on registration.
- Get verified early. Operator verification is a prerequisite for any registration. A company verifies with a qualified electronic seal from an EU qualified trust service provider, or with an electronic attestation of attributes issued under Union law (Article 4(2)). Verified status lasts at most three years and must then be repeated (Article 4(4)).
- Rehearse in the testing environment with one real product family before your deadline.
- Keep the audit trail. Store the registration confirmation with the passport.
MyProductPassport records the registry lifecycle on every passport: the unique product identifier submitted, the correlation ID, the registration identifier returned and an optional back-up copy hosted by a DPP service provider.
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