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Regulation update

The EU DPP Registry accepts battery passports: what the upload actually asks for

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The registry now has a Batteries product group. Enrolment takes a qualified seal and exact matching; the registration file holds one field per passport. What we learned by enrolling OrigoPass itself.

The EU Digital Product Passport Registry opened on 20 July 2026 under Implementing Regulation (EU) 2026/1778. Several guides still say that battery passports cannot be registered in it yet. That is no longer true: the registry now offers Batteries as a product group, covering industrial, EV and LMT batteries, and accepts registrations. We enrolled OrigoPass in the registry this week and went through the whole procedure, so here is what it actually asks for.

What the registry is, and is not

The registry is an index. It stores the unique identifier of each passport and the address where the passport is hosted, nothing else. The passport data, the documents and the access tiers stay with the platform that hosts the passport. The registry runs an automatic format check on every submission and explicitly states that this is not a compliance check. On success it returns a registration identifier and a sealed proof of registration.

Step 1: the operator enrols, once

Only a verified economic operator may register passports: the company that places the battery on the EU market. Enrolment is done at registry.product-passport.ec.europa.eu with an EU Login account. The registry generates a declaration with the organisation's name, address, country and identifier, sealed by the European Commission. The operator countersigns that PDF with a qualified electronic seal (a company) or a qualified electronic signature (a sole trader) from a trust service provider on the EU trusted list, and uploads it. The verified status lasts as long as the certificate, at most three years. There is no fee and no licence.

Two things cost most of the time. Ordering the seal or signature takes days, so start there. And the name, country and identifier in the certificate must match the declaration exactly; the registry compares them literally. A sole trader's certificate, for example, carries the trust provider's own identifier rather than a tax number, and that is the value the registry wants in the form.

Step 2: one field per passport

The registration file is as small as it gets. The registry publishes a JSON and an XML template; both contain a schema version, the product group and a list of items with a single field each: the unique product identifier, which is the https address printed in the passport's QR code. A file holds at most 100 passports. Alternatively the operator types one passport at a time in a form.

Step 3: the answer

The registry's Activity Dashboard shows whether a batch was accepted and gives the registration identifier. A proof of registration, sealed and time-stamped by the Commission, can be downloaded for 90 days and generated again later.

What OrigoPass does with this

The console has a registry page that produces the batch file in the registry's own format for the passports that are not registered yet, and tracks the status of every passport: not yet in a file, in a batch awaiting the registry's answer, registered with date and reference. Confirming a batch is a sealed record in the customer's audit ledger, so the registration date can be proven later. Article 13 pages are not passports and never go in; withdrawn passports are left out.

The regulation foresees third parties registering on an operator's behalf, and the registry mentions an API. Neither is worked out yet: the API specification is not published, and the rules for service providers under the Ecodesign Regulation are expected in 2027. Until then the operator uploads the file under its own verified account, a few minutes per batch of 100, and we do not promise more than that.

Sources

This update is general information, not legal advice. The sources above are authoritative; this page is our reading of them.