On May 21, 2026, the European Commission submitted a significant draft regulation to the Technical Barriers to Trade (TBT) Committee of the World Trade Organization (WTO) (Notification No.: G/TBT/N/EU/1211), proposing detailed implementing arrangements for the Digital Product Passport (DPP) registration system under the framework of the Ecodesign for Sustainable Products Regulation (ESPR).
Once the draft is formally adopted, all enterprises exporting relevant products to the EU—whether located within or outside the EU—must adapt to a completely new digital compliance process. CIRS Group provides the following interpretation of this registration system draft.
I. Scope of Application
This registration system applies to Digital Product Passports for the following products:
- Sustainable products: Products covered by the delegated acts under (EU) 2024/1781
- Batteries: Pursuant to Article 77 of (EU) 2023/1542
- Construction products: Pursuant to Article 76 of (EU) 2024/3110
- Toys: Pursuant to Article 19 of (EU) 2025/2509
- Detergents: Pursuant to Article 21 of (EU) 2026/405
- Other products for which EU legislation requires the use of a Digital Product Passport
II. Main Components of the Registration System
The system comprises nine core components:
- Secure user interface website (for economic operators, value chain participants, national competent authorities, and customs)
- API interfaces (for registering Digital Product Passports and receiving information)
- Verification platform (to confirm and verify the existence and integrity of Digital Product Passports)
- Unique registration identifier generation scheme
- Commodity code storage (for products intended to undergo "free circulation" customs procedures)
- Digital Product Passport service provider list (service providers hosting backup copies)
- Semantic Repository
- Logging system
- Identity recognition and authorization scheme
III. Identity Verification Requirements
|
Entity Type |
Established in the EU |
Not Established in the EU |
|
Natural persons (self-employed persons) |
Qualified electronic signature OR High-level electronic identification OR Electronic attribute proof under EU law |
Qualified electronic signature OR Electronic attribute proof under EU law |
|
Legal persons |
Qualified electronic seal (issued by a qualified trust service provider) OR Electronic attribute proof under EU law |
Qualified electronic seal OR Electronic attribute proof under EU law |
- Verification status validity: Maximum 3 years (until the expiration of the electronic identification means or the 3-year period, whichever comes first)
- Only verified economic operators can register Digital Product Passports in the registration system
IV. Digital Product Passport Registration Process
- Registration entity: Economic operators placing products on the market or putting them into service
- Registration granularity: At least to the level required by the applicable legislation (model, batch, or item level)
- Item-level registration: Must also link batch and model identifiers
- Batch-level registration: Must link the model identifier
- Unique products (e.g., handmade goods): No batch or model identifiers required
- Registration method: Via secure user interface or API
- Automatic verification content:
- Existence and semantic compliance of mandatory data
- Granularity level compliance
- Commodity code validity
- Backup links (where applicable)
- Use of qualified electronic signatures/seals
- Registration result: Generation and storage of a unique and persistent registration identifier
V. Registration Proof
- Economic operators may generate registration proof for registered Digital Product Passports at any time
- The proof is a secure electronic document containing: registration identifier, commodity code, registered operator information, registration date and time, Digital Product Passport version hash value
- Guaranteed by the European Commission's qualified electronic seal and qualified time stamp
- Valid for 90 days, renewable
VI. Data Management
- Version control: Each new version links to the original registration identifier and stores a time stamp
- Data retention:
- Where no specific retention period is stipulated by legislation: Automatic deletion 10 years after registration
- Where a specific period is stipulated: Retained according to that period
- Supports data updates and deletions; all changes recorded in the logging system
VII. Semantic Repository
- An authoritative machine-readable data source established and maintained by the European Commission
- Contains data models, semantic definitions, and vocabularies
- Provides search services, accessible via public API
- Free and open for use
- Compliant with DCAT-AP specifications
VIII. Logging System
Records activities in the following categories:
- Access and authentication data (retained for 6 months)
- Data modifications (retained until the end of the registration period)
- Administrative operations (retained for 5 years)
- Data exchanges (retained for 5 years)
ChemRadar Insights
According to the notification, the deadline for comments on this draft is June 15, 2026, leaving industry less than one month to provide feedback. The European Commission plans to formally adopt this regulation on July 19, 2026. The regulation will enter into force on the 20th day following its publication in the Official Journal of the European Union. From applying for qualified electronic seals, interfacing with APIs, to ensuring product data complies with Semantic Repository standards, enterprises face significantly increased technical investment and compliance requirements.
CIRS recommends that enterprises: Immediately initiate the application process for qualified electronic seals/signatures (especially non-EU enterprises); assess the compatibility gaps between existing ERP/PLM systems and the EU Semantic Repository; develop or procure API interfacing tools to establish automated data channels with the registration system.
