What is the register of digital product passports and what do I need to enter in it?

The register links a product passport to a unique number

The European register of digital product passports is not a copy of the passport itself, but a central index that records which passports exist and to which product, manufacturer and registration they are linked. Article 13 of the ESPR (Regulation (EU) 2024/1781) requires the European Commission to establish and manage this register. Whoever places a product with a digital product passport on the market must have the corresponding basic data included in that register, so that supervisory authorities, customs and market participants can verify whether a passport is actually registered. Additionally, Article 14 provides for a web portal: the technical facility through which the data from the passport itself – that is, the substantive product information – can be consulted by those who have access to it. The register (Article 13) and the web portal (Article 14) are therefore two different building blocks of the same system: one is the index, the other is the gateway to the data.

For electronics, this applies per product category, not all at once

This registration obligation applies to products for which the ESPR requires a digital product passport, and this is regulated separately per product group via delegated acts. For electronics and ICT equipment, this means that the obligation only arises once the Commission has adopted a delegated act for the relevant subcategory – for example for white goods, or for a specific type of ICT equipment. Without such an act for a particular product group, there is no registration obligation for that group yet, even though the ESPR as a framework regulation is already in force. This is therefore not a general, directly applicable obligation for all electronics at once, but an obligation that comes in gradually, product by product. Anyone currently importing or manufacturing ICT equipment or white goods cannot therefore assume that a registration obligation already applies, unless their own product group has been specifically designated.

No fixed date is set yet; the work plan does indicate the sequence

There is no fixed date yet for when the registration obligation for electronics and ICT equipment comes into force. The ESPR work plan 2025-2030 indicates that delegated acts for product groups such as these are expected to be published from 2027 onwards, separately per subcategory. As long as such a delegated act does not exist, it is certain that the register and web portal exist as a system (Articles 13 and 14 of the ESPR are already adopted), but not when a specific product group will be required to use them. Once the Commission publishes a delegated act for a subcategory, it will also contain the date on which the obligation for that category comes into force. Until then, there is no legal obligation to register yet, and preparation is mainly a matter of getting data in order, not meeting a deadline that is already fixed.

What an entrepreneur can practically do with this

For those who wish to prepare for this, the first step is to find out whether and when your own product category is already covered by a delegated act under the ESPR – this determines whether and from when registration is required. The second step is to check which basic data will be needed to link a product to a passport and a registration number: these are typically identifying data about the product, the manufacturer or importer, and the place of business. Because the register (Article 13) is separate from the web portal (Article 14), it is wise not to confuse the two: registration ensures that a passport is findable and verifiable, the web portal ensures that the content of the passport is actually accessible to those who have the right to access it. If you have the passport compiled by a third party, it is advisable to ask in advance how that party handles registration in the European register and the link to the web portal, so that this is not forgotten as a separate, later step. Finally, it is useful to keep track of the publication of the delegated act for your own product group, as it will specify not only the registration obligation but also the start date and any transition periods.

The legal basis: Article 13 and Article 14 of the ESPR

These obligations follow directly from the ESPR itself: Article 13 of Regulation (EU) 2024/1781 governs the register of digital product passports, and Article 14 of the same regulation governs the web portal through which data from the digital product passport can be accessed. Both articles are part of the framework regulation and thus apply in principle to all product groups for which a digital product passport is required; the specific implementation for each product group – including the entry into force date for electronics and ICT equipment – follows from the delegated acts that the Commission establishes for each sub-category.

If you want to prepare now, the best approach is to identify your own product category and keep track of the publication of the corresponding delegated act, and in the meantime sort out internally which identification and registration data are available once that act is published.

What this is based on

The regulation itself is on EUR-Lex. We provide references per statement; you do not have to take our word for it.

What you must concretely do

What is expected of you

Article 13 of the ESPR (Regulation (EU) 2024/1781) introduces a central register in which certain data from the digital product passport are entered once that passport becomes mandatory for a product group. Article 14 describes, furthermore, a web portal through which market surveillance authorities and other stakeholders can access those registered data. For electronics and ICT equipment this is not yet active: the register and the portal will be populated per product group, at the moment the delegated act for that group enters into force. What is set out below is therefore a description of the mechanism as the regulation establishes it, not an obligation that applies to electronics today.

Register data before the product reaches the market

The regulation provides that part of the data from the product passport is entered into the register before the product is sold. For an electronics importer or manufacturer of large household appliances, this means in practice that the product passport is not something that is "filled in" afterwards, but that the core data are already fixed at the moment the product reaches the market. For a company with 10 to 100 employees, this is primarily a process matter: who in the organisation ensures that the correct data are ready in time, and how is it prevented that a product launch is delayed because the registration still needs to happen.

The unique identification code as a link

The register operates via identification codes that link the product, the operator and the passport itself. Without a conclusive identification code per product there is a risk that data in the register do not align with the passport displayed via the QR code. How that code looks and when it is unique enough is described on the page about how each product receives a unique identification code. For companies that already work with GS1 structures, there is an interface with the question whether that system is sufficient for this purpose, elaborated on the page about GS1 Digital Link.

Accessibility for market surveillance authorities via the web portal

Article 14 describes a web portal intended for consultation by, among others, market surveillance authorities and customs. For a company this means that registration is not only an administrative step, but also the place on which supervision can be based. That is a different practical reality than a passport that is viewed only by consumers via a QR code: the portal makes data systematically searchable for authorities, not only incidentally accessible per product.

Registration separate from, but dependent on own hosting

The register does not replace the hosting of the product passport itself: the regulation is based on a system in which the passport remains with the operator (or a service provider on behalf of the operator), and the register takes over a limited set of data from it. That touches on the question what the hosting of a product passport must comply with: the registration obligation in Article 13 adds an additional destination for data, in addition to the hosting that is already needed to keep the passport itself available.

Where things go wrong in practice

A number of recurring situations can now already be foreseen, even though the delegated act for electronics is not yet there:

Registration data and passport data drift apart. When a product passport is adjusted after sale (for example by a firmware update or a revised repair guide), but the corresponding register data are not updated, a difference arises between what the register shows and what can be found via the QR code.
The identification code is assigned too late or inconsistently. If the product is manufactured first and the code is only determined afterwards, there is a risk that the same code is accidentally used on multiple variants, or that a product series leaves the facility without a code.
Responsibility for registration is not assigned. In companies where multiple departments (procurement, quality, IT) each manage part of the product data, there is sometimes no clear owner for the step "this goes to the register". This leads to delays just before market introduction.
Confusion between the supervision portal and the passport for the consumer. Some companies assume that setting up a consumer-facing passport automatically satisfies the registration obligation, while the register is a separate mechanism with its own purpose for the data.
Systems that are not aligned with each other. When product data already exist in an ERP or inventory system, but are not structured according to what the register will require, that translation must happen manually each time. This connects to the question of whether the passport can be linked to an existing ERP or inventory system: a properly configured link prevents registration from becoming a separate, error-prone exercise.

What you can document

Even without the delegated act for electronics already in place, it is practical to put a number of things in order now, so that the transition to a registration obligation does not require restructuring of the foundation:

An overview of which product data are already centrally recorded, and which of those correspond to what Article 13 mentions for registration.
An established method for assigning identification codes per product, including who within the organization assigns and manages that code.
An indication of who is responsible for maintaining the registration data when a passport is modified after market introduction.
An overview of the systems (ERP, inventory management, quality files) in which product data already exist, with a note on which of those can be used as a source for the register.
A template for the dataset per product group, so that when the delegated act is published it is quickly clear which fields are already available and which are still missing.

For products that consist of separate components or are sold in packaging with multiple units, it is also useful to determine now how that relates to one registration unit; this connects to the questions about how the passport works with a box containing multiple devices and about cooperating passports for one product.

This is not legal advice. This page provides general information about the regulations that this platform covers. We are not familiar with your situation. If you are in doubt about your own case, consult a lawyer or the competent supervisory authority.

Written with AI based on the sources above, checked by a human on 2026-08-22. Is something incorrect? Let us know — corrections take priority.