The European Commission's central Digital Product Passport registry went live this past weekend. It does not create any new obligation for battery manufacturers today. The date that matters is 18 February 2027, from which every in-scope battery placed on the market or put into service in the EU must have a battery passport, and the economic operator placing it must upload that passport's unique identifier to the registry. The rules governing how that registration works were published three days earlier as Commission Implementing Regulation (EU) 2026/1778, and they contain one requirement that most manufacturers have not yet planned for.
Before a company can register anything, it has to be verified as an economic operator, and it proves that status with a Qualified Electronic Seal issued by a Qualified Trust Service Provider under the EU’s eIDAS framework. Obtaining that seal is quick, but it is the one step in the chain that no software provider can complete on your behalf. Everything that follows, from building the passport data to sealing it and submitting it to the registry, is work that we at Minespider can handle for you inside the platform.
What actually went live?
Article 13(1) of the Ecodesign for Sustainable Products Regulation (Regulation (EU) 2024/1781) required the European Commission to have the registry set up by 19 July 2026, and it has done so. The registry, its testing environment and the Commission’s user guidelines are all now available to economic operators.
The operating rules arrived shortly before it. Commission Implementing Regulation (EU) 2026/1778 was adopted on 16 July 2026, published in the Official Journal on 17 July, and enters into force on 6 August. It sets out the registry’s structure, the identity verification standard behind it, how registration works, what proof of registration you receive, and how long the Commission retains your data. It is the first document that describes how registration will work in practice rather than in principle, which is why it is worth reading carefully even though the obligation itself is still some months away. The full text is available in all 24 official EU languages under the permanent identifier data.europa.eu/eli/reg_impl/2026/1778/oj.
Three dates are circulating at the moment and it is easy to conflate them, so it is worth separating them out. 19 July 2026 was the Commission’s own legal deadline to have the registry established. 20 July 2026 is the date the registry, its testing environment and the user guidelines became available to users. 6 August 2026 is the date Implementing Regulation (EU) 2026/1778 formally enters into force.
None of these dates makes a passport mandatory for your product. That obligation still comes from the law covering your specific product category, which for batteries is Article 77(1) of the EU Battery Regulation (Regulation (EU) 2023/1542), with a date of 18 February 2027. The registration obligation itself sits in Article 77(10), which requires the economic operator placing the battery on the market or putting it into service to upload its unique identifier to the registry.
Which products the registry covers
Article 1 places the following categories in scope from the outset, and the list will grow as further ESPR delegated acts are adopted:
- Batteries, meaning EV batteries, LMT batteries and industrial batteries with a capacity above 2 kWh, under Article 77 of the EU Battery Regulation
- Construction products, under Article 76 of Regulation (EU) 2024/3110
- Toys, under Article 19 of Regulation (EU) 2025/2509
- Detergents and end-user surfactants, under Article 21 of Regulation (EU) 2026/405
- Any product category covered by a future ESPR delegated act, or by any other Union law that requires registration in this registry
The term digital product passport includes the battery passport established under the Battery Regulation. Everything described below therefore applies directly to battery manufacturers, and it applies now rather than at some indefinite point in the future.
The identity requirement, and why it matters
The regulation introduces the concept of a verified economic operator, and this is the part of the regulation that has the most immediate practical consequence. Before any passport can be registered, the operator behind it has to prove who it is, and it proves this not to a software platform but to the European Commission, through the EU’s trust services framework set out in Regulation (EU) No 910/2014, better known as eIDAS.
For a company, the accepted proof is a Qualified Electronic Seal, usually shortened to QES. A QES is not a certificate you download and pass around your organisation. It is a cryptographic key held inside a secure facility operated by a Qualified Trust Service Provider, which is a regulated and audited entity that functions in practice rather like a digital notary. When a document needs to be sealed, an API call sends a cryptographic hash of that document to the provider and a sealed hash comes back, while the key itself never leaves their infrastructure.
Only a Qualified Trust Service Provider can issue a QES, which means that no digital product passport platform can issue one and none can complete the verification on your behalf. If a vendor tells you otherwise, they have misread the regulation. Verified status then lasts until the underlying electronic identification expires, and in no case longer than three years, after which the operator re-verifies in order to keep registering or modifying passports.
The five steps to a registered battery passport
This is what we anticipate the process to look like - Minespider handles three of the five steps, and the two on the client side are a one-off identity check and a one-off authorisation.
- In the coming weeks Minespider will select a Qualified Trust Service Provider partner, who will provide Qualified Electronic Seals to Minespider and to our clients.
- Each client obtains its own QES. This is the identity check described above, and it is the only step that has to be completed by the operator itself.
- Minespider registers in the EU portal as a verified third party, acting on behalf of its clients.
- The client logs into the portal and authorises Minespider to seal and register passports on its behalf. The regulation provides for third parties to perform registration actions on an operator's behalf once verified under Article 19(4), with the operator remaining fully responsible for what is submitted.
- From that point onwards, every passport created in Minespider is sealed and submitted to the registry automatically.
Steps two and four are the items on your side, and both are one-off. It is worth planning for them early. The identity check itself is fast, but internal approval for anything involving a company seal rarely is, and it is far easier to have this settled well before your data work is finished than to discover the requirement in the final weeks before February 2027.
When we began mapping this integration, the honest expectation inside the company was that it would be considerably more painful than it has turned out to be.
“The EU DPP Registry is a milestone we were all waiting for. It provides a central index for authorities, and establishes the unified standards we need to build secure, role based DPP access control.”
Nathan Williams, Founder & CEO, Minespider
What happens when a passport is submitted
On submission, the Commission validates the registration data under Article 8(7) and (8) before the registration takes effect.
Once registered, the operator can request a proof of registration, an electronic document guaranteed by a qualified electronic seal under Article 38 of eIDAS and carrying a Commission time stamp. It is made available through the registry's secure interface or the API and remains available for 90 calendar days. Registration data itself is deleted automatically ten years after registration, unless the product-specific law sets a different retention period.
Two things the registry does not do
The first is that it does not confirm your product is compliant. The regulation is explicit that the automated check verifies structure and completeness only, and that passing it is not evidence that the product itself meets the requirements of the law that made the passport necessary. Substantive verification remains a market surveillance function, and market surveillance authorities will now have a single indexed place in which to look.
The second is that it does not build your passport for you. The registry stores identifiers and metadata that point at a passport already existing elsewhere, hosted by you or by your provider and resolvable on request. Creating that passport is work, and it involves mapping your technical documentation to the applicable data model, obtaining the fields that only your upstream suppliers can provide, and hosting the result to a standard the registry can resolve against. That work is measured in months rather than minutes, and it is where the real deadline risk sits. Registration, once the underlying data exists, is a short procedural step.
A date worth marking
Member States have until 18 February 2027 to appoint a designated national administrator responsible for managing their country’s access rights to the registry. That is the same day the battery passport becomes mandatory under Article 77(1) of the Battery Regulation, which means the national access infrastructure and the first hard product deadline arrive together, with no phase-in period behind them.
What we would suggest doing next
- Begin the process of obtaining a Qualified Electronic Seal for your legal entity, and treat the internal approval rather than the identity check itself as the part that takes time.
- Once your seal is issued, authorise Minespider in the EU portal so that registration can be handled on your behalf.
- Work on your passport data in parallel, since supplier data gaps close slowly and no amount of registry readiness compensates for a passport with nothing in it.
If you are already working with us on Battery Passports, we will be in touch directly about the seal, including which provider we have selected and how to move through the process quickly. If you would like to understand what the February 2027 deadline means for your specific product range, our Digital Battery Passport guidance is a good place to start, and a discovery call is the fastest way to get an answer specific to your company.
