The Digital Product Passport registry is live, and customs can query it

What happened. The registry required by Article 13 of the Ecodesign for Sustainable Products Regulation — Regulation (EU) 2024/1781, which set a deadline of 19 July 2026 — is live and enrolling organisations. Before a product in scope can be placed on the EU market, the relevant economic operator must register its Digital Product Passport and receive a unique registration identifier.

The detail worth reading twice. The registry does not store the full passport. It stores unique identifiers, registration data and high-level metadata, hosts the harmonised data models — and lets customs authorities verify electronically that an imported product has a valid registered passport and a commodity code before release for free circulation. That converts a data obligation into a border control, which is a materially different kind of risk from a fine.

Who carries it. The obligation sits with the economic operator placing the product on the market. For own-brand and direct-import ranges, that is the retailer. Article 30 separately requires dealers reselling third-party brands to make the passport easily accessible to customers, including in distance selling. Article 10 requires the operator to give a dealer or marketplace a digital copy of the data carrier or identifier within five working days of a request, free of charge.

The standard being set. Article 9(1): the data “shall be accurate, complete and up to date”. Article 10 requires it machine-readable, structured, searchable and transferable, on open standards, tied to a persistent unique identifier. Annex III names the elements — including GTIN in line with ISO/IEC 15459-6, TARIC commodity codes, manuals, warnings and safety information, importer EORI number and a unique operator identifier.

Sequence, as currently planned. ESPR is a framework: the passport becomes mandatory product group by product group through delegated acts, each with a transition period of at least eighteen months after adoption. The Commission’s indicative timeline has certain batteries first in February 2027 under the Batteries Regulation, construction products in Q2 2027, textiles, aluminium and tyres across Q3–Q4 2027, furniture in 2028 and mattresses in 2029. Treat these as the Commission’s plan rather than settled law — ESPR acts have slipped before.

Separately, and sooner. The ESPR ban on destroying unsold clothing and footwear applies from 19 July 2026, with the delegated and implementing acts adopted 9 February 2026 and the standardised disclosure format applying from February 2027.

So what. If your first affected category is textiles or furniture, you have a supplier data programme with an eighteen-month-plus runway and a customs checkpoint at the end of it. The useful question this quarter is not “when is our deadline” but “which of our suppliers can produce machine-readable attribute data at all, and what does our contract say if they cannot”.