Introduction
Over the last two years, much of the discussion around Digital Battery Passports has focused on data collection, carbon footprint declarations, due diligence obligations, and supplier engagement. However, with the publication of the draft Digital Product Passport (DPP) Registry Implementing Act as part of the Ecodesign for Sustainable Products Regulation (2024/1781), the conversation is gradually shifting towards a new question: How will Digital Battery Passports actually function within the future EU ecosystem?
As the EU DPP Registry is expected to become operational on 19 July 2026, this question is becoming increasingly relevant. While several technical standards and implementing acts are still evolving, the draft Registry Implementing Act provides a direction on how Digital Product Passports (DPPs) are expected to be registered, authenticated, and linked to economic operators, laying the foundation for the future European DPP framework.
What is the DPP Registry?
One of the most common misconceptions we encounter is that the DPP Registry will become a central database containing all Digital Battery Passport information. Based on the current draft, this is not the intention.
The Registry is expected to function as a registration, verification, and interoperability layer rather than a repository of all passport content. Similar to how a domain name system helps users locate a website without hosting it, the Registry is expected to help register, identify, verify, and reference Digital Product Passports while the actual Digital Battery Passport remains hosted by a DPP provider.
What is Already Defined vs What is Still Evolving?
One of the challenges with the Registry is that some elements are already clearly defined while others are still expected to evolve through future implementing acts and guidance.
Already relatively well defined are the:
- Registry registration processes
- Verified Economic Operators
- eIDAS-based trust mechanisms
- Semantic conformity requirements
- Proof of Registration concepts
Still evolving:
- Access rights and stakeholder permissions
- Customs integration workflows
- Product-specific semantic requirements
- Operational onboarding processes
- Interactions between different DPP ecosystems
What Information is Expected to Be Registered?
Based on the draft act, the Registry is expected to contain registration identifiers, product identifiers, model, batch and item relationships, commodity codes, timestamps, registrant information and proof-of-registration information. However, it is worth noting that the Registry is not expected to duplicate the full Digital Battery Passport dataset.
Responsibilities: Economic Operator vs DPP Provider
The economic operator placing the battery on the EU market remains responsible for the Digital Battery Passport, the underlying data, and the related compliance obligations. The Registry does not transfer those responsibilities.
The role of the DPP provider is expected to focus on the technical infrastructure: passport hosting, registry integration, API connectivity, interoperability, semantic conformity support, and future operational workflows.
Verified Economic Operators and eIDAS
The concept of the Verified Economic Operator (VEO) is one of the most discussed elements of the draft act. Based on the current draft, this should be understood primarily as a trust and identity mechanism rather than a product certification scheme.
The framework references eIDAS (electronic IDentification, Authentication and trust Services) trust services such as electronic signatures, electronic seals, and future digital credentials. Additional operational details are still expected to be clarified following final adoption of the act.
Semantic Conformity: The Hidden Challenge
Historically, many compliance projects have focused on collecting data. The Registry introduces an additional requirement: ensuring that the data follows agreed structures, definitions, and formats so that over time data can be consistently interpreted, exchanged, validated and compared across systems.
The future Semantic Repository maintained by the European Commission is expected to contain common data models, multilingual definitions, controlled vocabularies, and interoperability specifications. For companies, this is where successful compliance may therefore depend not only on having the data but also on structuring it correctly.
Access Rights: The Next Major Discussion
Who gets to see what part of the Digital Battery Product Passports is one of the main questions we receive daily. Access rights remain one of the most common topics raised by manufacturers. While the Registry Draft Act focuses on registration and interoperability, Article 77(9) of the EU Battery Regulation requires a separate implementing act defining who can access what information and under which conditions.
Questions regarding authorities, recyclers, repairers, second-life operators, battery owners, and service providers and to which extent they can access the passport are therefore expected to become increasingly important as the regulatory framework develops. Further details are expected through a separate implementing act to be published in the course of August 2026.
Common Questions We Receive from Clients - and Our Responses:
- Can a DPP provider register on behalf of the manufacturer?
A DPP provider can, from a technical perspective, potentially handle registration on behalf of a manufacturer, but responsibility is expected to remain with the economic operator. - Will customs have access to the full Battery Passport?
Customs access to the full Battery Passport is not currently defined in the draft framework. What market surveillance and customs authorities will be able to see, and at what level of detail, remains to be clarified as the implementing acts and technical specifications develop. - Will all Battery Passport data be publicly visible in the DPP registry?
The DPP registry is not expected to make all Battery Passport data publicly visible. Current indications point toward the registry storing registration information and identifiers — such as the registration identifier and product unique identifiers — rather than the full passport content, which remains with the manufacturer or its provider and is accessed through the passport's own tiered access layers. - Is the Verified Economic Operator a product certification?
The Verified Economic Operator is not, based on the current draft, a product certification. It appears focused primarily on identity and trust — establishing who an operator is and that they can be relied upon — rather than on certifying the characteristics or compliance status of a specific product. - How do we register Digital Battery Passport data in the DPP Registry?
- Before registering a Digital Battery Passport, the responsible economic operator will first need to obtain the status of a Verified Economic Operator. Once the passport has been created and hosted by a Digital Product Passport service provider, it can be registered in the EU DPP Registry either through the Registry interface or via API.
- The Registry will automatically validate the submitted information and, upon successful verification, generate a persistent registration identifier. The Battery Passport itself remains hosted outside the Registry, while the Registry acts as the central registration and identification layer.
As a Digital Product Passport service provider, Minespider enables customers to create, host and manage Digital Battery Passports while supporting their registration in the EU DPP Registry. Customers can either use the Minespider platform directly or integrate their internal systems through Minespider APIs. Minespider can also offer an integration layer as a service to support automated registration and synchronization with the EU DPP Registry.
What Happens If Companies Are Not Ready?
The Registry itself should be viewed as an operational component of the broader Digital Product Passport framework rather than a standalone compliance regime.
In practical terms, companies that are unable to generate compliant Digital Battery Passports, maintain required information, or complete future registration and verification processes may face challenges when placing products on the EU market, responding to customer requests, supporting audits, or demonstrating compliance to market surveillance authorities.
For many organisations, the greatest risk is therefore not necessarily a regulatory penalty on day one, but finding themselves with insufficient time to establish governance processes, collect supplier data, implement technical solutions, and prepare for the operational requirements that continue to emerge.
Key Takeaway
The DPP Registry should not be viewed as a separate compliance project. For most battery manufacturers, Registry readiness, Battery Passport readiness, supplier readiness, and data-governance readiness are increasingly becoming part of the same implementation journey.
Timeline
July 2023: EU Battery Regulation adopted.
June 2024: ESPR adopted.
April 2026: Draft DPP Registry Implementing Act published.
Expected July 2026: Adoption of the final Registry Implementing Act.
Expected 19 July 2026: Registry operational launch.
18 February 2027: Battery Passport obligations become applicable for relevant battery categories.
