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Unique identifiers
GS1-compliant product identifiers at the right granularity (model, batch or individual item, EN 18219) – maintained consistently in ERP and PIM.
Infrastructure · Deadline: 19 July 2026
By 19 July 2026 the European Commission must set up the central registry for Digital Product Passports (ESPR Art. 13) – launch is imminent. Once the delegated act for your product group applies, registration is a precondition for placing products on the market – not a downstream administrative step. Here is how it works.
01 — How it works
The most common misconception first: the EU registry is not a central product database. Your passport data stays hosted decentrally with you (or your DPP service provider). The registry is a directory: it links the unique product identifier to the place where the passport can be retrieved.
The registration flow:
Registration must happen before the product is placed on the EU market or put into service. That effectively turns the product passport into a market-access condition – customs will also be able to check against the registry in future.
02 — Consequences
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GS1-compliant product identifiers at the right granularity (model, batch or individual item, EN 18219) – maintained consistently in ERP and PIM.
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A hosting concept for machine-readable passport data across the entire product life cycle – including availability, versioning and archiving.
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A process that registers new products automatically – manual handling stops scaling beyond a few dozen articles.
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Tiered views for consumers, authorities and recyclers in line with the delegated act and the EN standards.
We build identifier logic, data provisioning and API processes with you – tested right away as part of the pilot product passport.
03 — FAQ
Only if your product group is already subject to the obligation – as of July 2026 that applies to no one yet; battery manufacturers are first, on 18 Feb 2027. What makes sense now: prepare identifiers, data hosting and API processes so that registration later runs on autopilot.
The registry itself is EU infrastructure; as things stand, no EU fees apply for registration. The real costs sit in your own house: identifier logic, data provisioning, API connection and ongoing maintenance.
GS1 Digital Link has established itself as the standard for registration and is the most practicable route. The EN standards do in principle allow other standards-compliant identifier systems – but if you already use GTINs, GS1 is the smoothest path.
Responsibility lies with the economic operator placing the product on the EU market. For imports from third countries that regularly lands on the importer – who needs the supplier’s data to do it. That is exactly why importers should involve their supply chain especially early.
Contact
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Vincubate Ventures · Across the DACH region and Europe, remote & on site
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