Digital Product Passport: moving towards the operation of the European register

The European Commission has published Implementing Regulation (EU) 2026/1778, which lays down the arrangements for implementing the register of Digital Product Passports (DPP) provided for by Regulation (EU) 2024/1781 (Ecodesign for Sustainable Products Regulation - ESPR). The act, published in the Official Journal of the European Union on 17 July 2026, represents a fundamental step for the operation of the European digital passport system and constitutes the implementing measure provided for by Article 13(5) of the ESPR.

An essential component for the Digital Product Passport

The European register will constitute the central infrastructure intended to support the functioning of digital passports. The regulation defines the operational and technical rules necessary for managing the system, identifying roles, responsibilities and access procedures for economic operators, other actors in the value chain, competent authorities and customs authorities.

The aspects regulated include:

• the management of access to the register;
• the procedures for authentication and verification of economic operators;
• the requirements for registering products and the related digital passports;
• the generation and storage of unique identifiers;
• recording of the information necessary to ensure product traceability;
• the mechanisms for interoperability and data management;
• the systems for recording operations carried out in the register for the purposes of transparency and user accountability. 
  
  

A common infrastructure for multiple European regulations

The regulation confirms that the register will be used not only for products subject to the future delegated acts under the ESPR, but also for other European regulations that provide for the use of a digital product passport. These already include the Batteries Regulation, the Construction Products Regulation, the new Toy Safety Regulation and the new Detergents Regulation.

The objective is to ensure a harmonized infrastructure at European level, capable of supporting the collection and consultation of information throughout the entire product life cycle and fostering the circulation of reliable data among actors in the value chain.

What this means for companies

Although the regulation does not yet define the content that will have to be included in the digital passports for the different product categories, it establishes the technical and organizational framework within which companies will have to operate when the DPP requirements become applicable through the future sector-specific delegated acts provided for by the ESPR.

For the companies involved, it will therefore become increasingly important to set up systems capable of ensuring the correct identification of products, the management of traceability information and integration with future European digital infrastructures. The regulation in fact represents a further step toward implementing the model of transparency and circularity promoted by the ESPR and the European Green Deal.

Implementing Decision (EU) 2026/1736

Just two days before Implementing Regulation (EU) 2026/1778, Implementing Decision (EU) 2026/1736 was published. This act focuses on harmonized standards for digital product passports.

The references of the standards relating to the conformity requirements for DPPs provided for by Articles 10 and 11 of the ESPR Regulation are thus indicated in the Official Journal of the EU. In particular, these are 6 EN standards of the “182xx” series (EN 18216, 18219, 18220, 18221, 18222, 18223) relating to specific technical aspects of the DPP: data exchange protocols, unique identifiers, data carrier, data storage, archiving and persistence, APIs for managing the DPP life cycle, and interoperability of systems.

DPPs that comply with these harmonized standards are deemed compliant (as indicated in Article 41(2) of the ESPR Regulation) with the relevant requirements of Articles 10 and 11 of the ESPR Regulation covered by those standards.

The implementing decision entered into force on the day following its publication, i.e. on 16/07/2026.