The operational start in July 2026
On 20 July 2026, the European Commission announced that the Digital Product Passport Registry and a testing environment were live. That makes a central part of the EU DPP system operational, not only planned. In the same announcement, the Commission links the launch to the first mandatory battery-passport date of 18 February 2027 and states that economic operators must register each DPP. The significance of the July 2026 step is therefore practical as well as legal: the Registry now exists as the place where registration is expected to happen, and a test environment is available alongside it.
The live service did not appear on its own. The Commission’s news item points to Commission Implementing Regulation (EU) 2026/1778 of 16 July 2026, and the Publications Office identifies that act as laying down the implementation arrangements for the DPP Registry set up under Regulation (EU) 2024/1781. In the same month, the Commission also adopted Commission Implementing Decision (EU) 2026/1736 of 14 July 2026 on harmonised standards for digital product passports. Official sources thus separate three July elements clearly: an operational registry, a binding implementing regulation for its arrangements, and a distinct implementing decision on standards.
- 20 July 2026: the Registry and testing environment were announced as live.
- 16 July 2026: Implementing Regulation (EU) 2026/1778 set registry arrangements.
- 14 July 2026: Implementing Decision (EU) 2026/1736 addressed harmonised DPP standards.
Framework law, implementing acts and guidance
The wider legal base is the Ecodesign for Sustainable Products Regulation. On its ESPR page, the Commission says Regulation (EU) 2024/1781 entered into force on 18 July 2024 and introduced the Digital Product Passport. The Commission also describes the ESPR as framework legislation. That distinction matters because not every product-specific passport obligation sits directly in the framework text. On the Commission’s DPP page, product-specific requirements are said to come either through ESPR delegated acts or through separate sector-specific legislation, with batteries given as an example of the second route.
The battery document published on 21 August 2026 has a different status. The Commission presents it as guidance to support preparations for the Digital Batteries Passport, but states expressly that it is not an authoritative legal interpretation and does not introduce additional legal requirements. That means the July implementing regulation, the July standards decision and the August guidance cannot be treated as the same type of instrument. One is binding law on registry arrangements, one is an implementing decision on harmonised standards, and one is non-binding guidance for preparation.
- Regulation (EU) 2024/1781 has been in force since 18 July 2024.
- Product-specific DPP rules can come through ESPR delegated acts or separate sector legislation.
- The battery guidance of 21 August 2026 is not an authoritative legal interpretation.
Registration duty, interfaces and decentralised data
According to the Commission, economic operators must register each DPP in the Registry. The same official material says the Registry stores unique identifiers and mandatory registration metadata, while detailed product information remains decentralised with the operator or a DPP service provider. The Commission’s model is therefore not a single central store for all product data. Registration data sit in the Registry, but the fuller passport information remains outside it in decentralised records.
The Commission also states that registration is available through a secure user interface or an API. In addition, economic operators can request proof of registration as a secure electronic document for third-party or B2B evidence. The same launch notice says the Registry is intended to support both ESPR product groups and other Union legislation requiring DPP registration, including certain large batteries, construction products, toys, detergents and end-user surfactants. Officially described functionality therefore already covers access channels, evidence of registration and a scope that extends across more than one legal regime.
- Each DPP must be registered.
- Access channels named by the Commission: secure user interface and API.
- Proof of registration can be requested as a secure electronic document.
Battery deadlines and the official timeline
The first mandatory date identified by the Commission is 18 February 2027. Across the Commission’s Registry announcement, DPP overview page and August battery guidance, that date is linked to EV batteries, LMT batteries and industrial batteries above 2 kWh that are placed on the market or put into service. The July Registry launch is framed against the same deadline, which shows that battery passports are not only a future ESPR concept. They are the first area for which the Commission describes concrete mandatory application on a named date.
On the Commission’s DPP page, updated on 03 September 2026, the indicative rollout timeline extends beyond the July package. It lists September 2026 for an implementing decision on the remaining two DPP standards and Q4 2026 for an implementing act on battery access rights. The same page places sector-specific DPP requirements for iron and steel in 2026 and for textiles, tyres and aluminium in 2027. It also says economic operators will have a transition period of at least 18 months after the adoption of ESPR delegated acts. Because the Commission labels this schedule indicative, it provides timing context rather than a new enacted deadline.
- First mandatory DPP date identified by the Commission: 18 February 2027.
- Battery groups named by the Commission: EV, LMT and industrial above 2 kWh.
- Indicative next steps: September 2026 on two standards, Q4 2026 on battery access rights.
The 71 data points in the battery guidance
The Commission’s updated guidance of 21 August 2026 consolidates 71 data points for the Digital Batteries Passport. It classifies each data point by battery category as mandatory, optional, circumstance-specific or not required for February 2027. That structure does not create new law, as the same Commission notice says explicitly. What it does provide is an official preparation aid that groups battery-passport information in a consistent way across the covered battery categories ahead of the first mandatory date.
On the Commission’s broader DPP page, possible passport content is described only at a higher level and explicitly varies by product group. Examples named there include information on safety, origin, materials, repairability, environmental performance, reuse and recycling. Alongside those general content categories, batteries are covered by the 21 August 2026 guidance and its 71-point structure by battery category.
- 71 data points in the updated battery guidance.
- Status labels by data point: mandatory, optional, circumstance-specific, or not required for February 2027.
- Possible DPP content by product group includes safety, origin, materials, repairability, environmental performance, reuse and recycling.