TracePass
Regulatory

The EU DPP Registry who submits, and what it actually checks

Publishing a passport and registering it are two different acts, and only one of them is your software vendor's job. This page explains what the registry does, who owes the submission, and why nobody can complete it for batteries yet.

The EU Digital Product Passport Registry is a central index, not a database of passports. It stores a unique product identifier, minimal metadata, and a pointer to wherever the passport data is actually hosted. It does not store the passport itself, and it deliberately does not judge whether the passport is correct.

That distinction matters more than it first appears. A registry that accepts your link has confirmed the link resolves — nothing about whether the data behind it satisfies the Battery Regulation. Those are two separate problems, and only one of them is solved by registering.

What the registry accepts today

We register test submissions in the Commission's acceptance environment to know this first-hand rather than from a guide. Here is what the mechanical gates do, and where the process currently stops.

Batteries is the only product group offeredOther groups follow the ESPR working plan. The registry's UI presents batteries and nothing else.
The mechanical checks passIdentifier format, the https requirement, the domain, and live resolvability of the link are all verified on submission — and a correctly built file clears them.
Semantic validation is unavailableThe Commission has published the battery data model the registry validates passports against, but the registry's validator is not yet switched on, so it refuses rather than passing. No battery passport can complete registration today, from any provider. The Commission has said registration will be available to economic operators from February 2027.
The registry stores no passport dataOnly the identifier, minimal metadata, and the pointer. Your passport stays where it is hosted.

Whose duty registration is

The obligation sits with the economic operator placing the product on the EU market — normally the manufacturer, the importer, or the operator selling directly to an EU end user. It does not sit with the software they use to build the passport.

That operator may authorise another party in writing to act on its behalf for the passport, under Article 77 of the Battery Regulation. Registration in the EU DPP Registry is different: the Commission has said it cannot be delegated, so the operator registers itself. And no authorisation moves the responsibility: the operator remains fully liable for the accuracy of the data and remains its controller.

This is why publishing a passport with TracePass does not register it, and why the platform says so on every published battery passport rather than letting the silence imply otherwise.

What TracePass does today

Everything up to the submission itself, so the step you owe is an upload rather than a data-assembly exercise. The submission stays with you: the Commission has said registration cannot be delegated to a service provider, for batteries or for ESPR products, so we don't offer it.

  • The upload file, in the registry's own format

    Export a batch file for your published battery passports, shaped to match the registry's sample template, or get the address to paste into the registry's online form for a single passport. Only passports that would pass go into the file. On paid plans.

  • Recording the registry's answer

    Once you have submitted, record the result on the passport: mark it as registered in production (its operator details are then locked), record a test in the acceptance environment, or import the registry's results file. We record your statement; we do not check it with the registry.

  • A resolvable identifier the registry accepts

    Every passport carries a GS1 Digital Link that resolves over https. The link gate is the check most submissions fail; ours passes it in the Commission's own acceptance environment.

  • A readiness check before you submit

    The platform mirrors the registry's formal checks — mandatory fields present and approved, formats valid, the link live — so you find problems before the registry does.

  • Checks against the published battery data model

    The readiness check already tests battery passports against the data model the Commission published for the registry, and the passport is served in that format when the registry reads its link — so you see semantic gaps now, before the registry starts checking.

  • A compliance verdict the registry does not give

    The registry checks that your link resolves. Whether the passport is actually correct under the Battery Regulation is a separate question, and the one we answer.

Build the passport now, register it when the registry is ready

The February 2027 deadline is on the passport, not on the registry queue. The work that takes months — collecting supplier data, filling the mandatory Annex XIII fields, getting them approved — is the part you can start today.

Start a free passport