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 offered | Other groups follow the ESPR working plan. The registry's UI presents batteries and nothing else. |
| The mechanical checks pass | Identifier 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 unavailable | The Commission has not defined the semantic catalogue for batteries, so the validator has no schema to check against and refuses rather than passing. No battery passport can complete registration today, from any provider. |
| The registry stores no passport data | Only 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, under Article 77 of the Battery Regulation. But the authorisation moves the work, not the responsibility: the operator remains fully liable for the accuracy of the data and remains its controller, whoever presses submit.
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 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. Available on every plan, including free.
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.
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.
On the roadmap — submitting on your behalf
RoadmapNot built, and deliberately not sold as if it were. The regulation permits it two ways, and both wait on the Commission publishing the semantic catalogue — until then there is nothing to submit to.
Under our own verified status
With your written authorisation, TracePass submits as a verified value chain actor and is named in the registration record as your service provider. You never touch the registry.
Inside your registry account
You grant TracePass access rights in the registry and we operate within them. Lighter to set up; your account, your verified status, our hands.
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