Your client leaves. What happens to their battery passports?

Every authorised representative we speak to asks a version of the same question. If a client leaves, do their passports go with them? Do I hand something over? Does the registry need telling?

The answer is cleaner than most people expect, and it turns on a distinction the registry rules draw sharply.

Switching representative is not a transfer

An authorised representative never holds the obligation in the first place.

Commission Implementing Regulation (EU) 2026/1778 — adopted 16 July 2026, in force 6 August — lets a verified economic operator delegate access rights to third parties acting on its behalf. The operator remains responsible for what those parties do. The text is explicit: where an operator authorises a third party to perform registration actions on its behalf, that operator remains fully responsible.

So when a client moves from one representative to another, what changes is who can act. The economic operator is the same legal entity it was yesterday. The passports have not changed hands, because the party answerable for them never moved.

Practically: the outgoing representative's access is revoked, the incoming one is authorised, and the registry entry for the responsible operator is untouched. No transfer record. Nothing to notify.

This matters commercially as well as legally. A representative who believes they own their clients' passports will make promises they cannot keep. A client who believes switching representative puts their compliance at risk will stay somewhere they should leave.

What does trigger a transfer

The regulation carries a separate provision for the case where the responsible party genuinely changes. It reads, in full:

Registered digital product passports may be transferred to another verified economic operator or, where applicable, to a verified value chain actor that takes over the obligations from the previous actor in relation to those digital product passports from the date indicated for the transfer.

One sentence. The recitals give the intent: organisational change — merging, splitting, sale of all or part of the business, cessation of activities. If your company is acquired, or you sell the product line the passports belong to, the obligations move with it from a date you state.

Two constraints sit underneath that. The receiving party must already be verified — you cannot hand passports to an entity that has not completed identity verification under the registry's eIDAS route. And verified status is not permanent: it lasts until the electronic identification means expire, and in no case beyond three years.

The case most people miss

There is a second trigger, and it is the one worth knowing about now.

An operator that has not passed identity verification can still transfer its registered passports to one that has. The recitals say so directly, and add that the registry should not prevent a lawful transfer of ownership irrespective of the transferring party's own verification status.

Read that from the other side. If you are an importer who cannot get verified in time — a certificate that does not match your company record, a registration identifier in the wrong format, a corporate structure that does not fit the form — you are not stranded. There is a lawful route that puts your passports with a party who can carry them.

That is a real answer to a real problem, and it is available before February 2027 rather than after.

What the rules do not say

Here is where honesty is more useful than confidence.

The provision authorises transfer. It does not describe how to perform one. There are no prescribed fields, no evidence requirement, no consent mechanism, no defined effect on the transferring operator's record, and no published interface for doing it. The DPP Registry User Guide, published 17 July, does not mention transfer at all. No registry API reference documents the operation.

We expect that to be filled in — the article was added late in the drafting process, which is usually a sign that detail follows. But it is not filled in today, and anyone telling you they have a registry transfer process working is describing something that has not been published.

One related point for anyone handling second-life batteries: repurposing and remanufacturing do not work this way. The Batteries Regulation requires a new battery passport linked to the original, with responsibility passing to whoever places the repurposed battery on the market. That is supersession, not transfer, and it is a different mechanism entirely.

What to do before February 2027

Three things, none of which need the missing procedure.

Know which entity is the economic operator for every passport you touch, and record it as an identity rather than a name in a field. Track that entity's verification status and its expiry, because a lapse stops new registrations. And keep the evidence you would need if ownership ever moved — the succession document, the effective date, who accepted it.

If those three are in place, you are ready for the procedure whenever it publishes. If they are not, no procedure will save you.

Our platform is built on that separation: access, ownership and obligation modelled as three different things, because the regulation treats them as three different things. You can see how it fits together at /platform.