Registration starts with verifying your company, not your product

Most companies planning for the digital product passport (DPP) are planning around product data. Which fields, from which suppliers, in what format.

The first step is not about the product at all. It is proving who you are.

The order of operations

Implementing Regulation (EU) 2026/1778, which sets the rules for the EU DPP Registry and applies from 6 August 2026, establishes how economic operators interact with the registry. Access is not open. An operator has to be identified and verified before it can register anything, using trust services under the eIDAS framework, which in practice means a qualified electronic seal or equivalent.

That verification is an administrative process with a queue, a provider, and a lead time measured in weeks rather than hours. It happens once, and it gates everything after it.

Why a slow step at the front is worse than a slow step later

It is a hard dependency at the front of the chain. A company can have perfect product data and still be unable to register, because the seal is not in place. Teams that discover this late find that the one part of the project they cannot accelerate with effort or budget is the part sitting between them and the deadline.

It has a real deadline attached already. The battery passport is mandatory from 18 February 2027. Anyone in scope needs verified access before that, not on the day. Working backward through a verification lead time of several weeks, plus internal legal review of who holds the seal and who may act on it, the comfortable start date is well before the year of the deadline.

The questions this raises internally

Who holds the seal? A qualified electronic seal belongs to the legal entity, and someone has to be accountable for its custody and use. That is a legal and governance decision, not an IT one.

Which legal entity registers? Groups with multiple manufacturing entities, importers and sales companies across member states have to decide which entity is the economic operator for each product, because that is the entity that registers and carries the obligation.

Who can act on it? Registration will not be a one-off. Products change, ranges expand, passports are updated. The authority to act needs to be delegated in a way that survives people changing roles.

None of those questions are hard. They are just slow, because they involve legal, and they cannot start once the deadline is close.

What to do now

Identify the legal entity that places each product line on the EU market. Start the verification process for that entity rather than waiting until the product data is ready, since the two tracks run in parallel and only one of them depends on your suppliers. Then record who inside the company is authorised to act, before you need them to.

Junction handles the verification and the registration on behalf of its customers, which removes the administrative track from the critical path but does not remove the decision about which entity registers. That one stays with you.

Sources

• Implementing Regulation (EU) 2026/1778, registry rules, adopted 16 July 2026, in force 6 August
• 2026 per Article 24.
• Regulation (EU) 2023/1542 (Battery Regulation): battery passport mandatory 18 February 2027.