You cannot register a battery passport today. Verify anyway

Two beliefs are circulating since the EU's Digital Product Passport registry went operational on 20 July, and they cancel each other out. The first: the registry is live, so obligated companies had better start registering passports. The second, usually delivered with a shrug: you cannot actually register anything in it yet, so there is nothing to do.

Both are wrong, and we can say so from inside the system rather than from the press release. This week we took our own organisation through the registry's acceptance environment end to end — enrolment, sealed declaration, operator verification, and a batch registration submission. Here is what the registry will let you do today, what it will not, and why the open half is the half you cannot delegate.

What happened when we submitted

Registration first, because it is the shorter story. We submitted a batch file built on the Commission's own reference template — JSON, three passports, each identified by its resolvable passport URL. The file format was accepted: the registry parsed it, recognised every item and echoed our identifiers back correctly. Then every item returned the same error: semantic validation failed because the service is unavailable.

That is not our data failing a check. The registry's User Guide for Economic Operators states it plainly: successful registration for batteries is not currently possible, because the semantic catalogue for this product group has not yet been defined. Until the Commission publishes that catalogue, no economic operator — anywhere — can complete a battery passport registration. The submission machinery works up to the exact point where the Commission's own semantic layer begins, and stops there.

What is actually open: verification

The half of the pipeline that is open is operator verification — and unlike registration, this half has your name on it.

Under Implementing Regulation (EU) 2026/1778, only a verified economic operator can register passports. For a legal person, verification means evidencing your identity with a qualified electronic seal issued by a qualified trust service provider. Your platform can carry the submissions, the file formats and the API integration when it arrives. It cannot carry your identity. Verification is yours, it holds for at most three years, and it is now genuinely completable — we are through it, among the first operators to be.

It is also less trivial than the workflow diagram suggests, which is worth knowing before February compresses everyone's patience. Three findings from our own pass that transfer directly:

The seal type matters. A legal person needs a qualified electronic seal — an organisational credential — not a director's personal qualified signature. If your e-signature provider quotes you a personal QES, that is the wrong product.

The identifier matters, character for character. The seal certificate carries your organisation identifier in a standardised composite form: scheme, country code, registration number. The registry compares this against your organisation record as an exact string. A bare company number in your profile against a composite identifier on your certificate is a rejection — with an error message that names no field. That mismatch cost us three days and four rejected declarations; it can cost you none.

Your passport URLs are infrastructure, not decoration. The registry fetches the unique product identifier URL at validation time, and its documented failure causes include redirect chains and protocol downgrades. If your public passport links bounce through redirects today, that is a latent registration failure waiting for the day the semantic service switches on. Ours did, until this week. Now they resolve in one hop, because we found out on a Wednesday in July rather than a deadline week in February.

The reversal

So the contrarian reading of "the registry is live but registration is impossible" is this: the Commission has opened, deliberately or not, exactly the right half first. Registration is machinery — files, formats, an API — and machinery is what a platform absorbs on your behalf. Verification is identity, and identity is the one step no provider can do for you. The registry as it stands today is a runway for the personal half of the obligation, with the mechanical half switched off until the semantic catalogue lands.

The binding date has not moved: from 18 February 2027, every LMT battery, EV battery and industrial battery above 2 kWh placed on the EU market needs a registered passport, and the economic operator named on it carries the Article 77 liability — that stays true whoever operates the software.

If you are an importer placing non-EU-made batteries on the market, an authorised representative acting for a non-EU maker, or a manufacturer issuing your own passports, the sequence is short and unglamorous: procure the qualified e-seal for the legal entity, check the identifier on the certificate against your registry record character by character, verify once, and let the credential sit valid while the Commission finishes its half. We track exactly where each piece of the registry stands — verified from inside it, not summarised from announcements — on our registry readiness page: where the registry stands now.