The short version: the registry is a DPP look-up service, it stores no product data, and there is currently nowhere for a textile product to be registered. If you have questions or want to stay informed, get in touch, but users and customers of AWARE™ have nothing to worry about today - we’ll keep in touch about tomorrow. 

The long version:

The European Commission finalised the DPP registry in their ‘Implementing Regulation (EU) 2026/1778’ document. It takes legal effect today, the 6th of August, 2026 and they have switched on the registry itself with a separate testing environment and a full user guide. 

What exactly is the registry?

The DPP registry is a database the European Commission runs, holding - for each product placed on the EU market with a DPP - a unique identifier plus what's needed to confirm a DPP exists and is valid: a commodity code where relevant, a reference to whoever hosts the DPP, and a timestamped registration record. 

It does not hold product data, material data, supplier lists, or sustainability figures. That data stays wherever the passport is hosted, which for AWARE™ customers means with the AWARE™ platform locked down on public blockchain.

What is AWARE™'s role in the DPP registry?

Once AWARE™ is verified in the registry, we can register DPPs on a customer's behalf, and generate proof of registration for them. This will be a feature of joining the AWARE™ platform.

What we cannot do is verify a customer's identity. A brand or importer placing the product on the EU market does have to prove their identity to the Commission. This is because while AWARE™ can provide the DPP data the people responsible for the product on the market are responsible for the data.

Still, you only need to do this if you are the organisation placing the product on the EU market. If you are not responsible for this, if you only supply products or materials to other organisations in a supply chain you do not need to verify your identity to the EU. 

What do textile producers have to do today?

Nothing. The registry currently only offers "Batteries" as a product group, and even that isn't functional: the Commission states outright that battery DPPs can't be successfully registered yet, because the semantic catalogue for that product group hasn't been defined. We expect this will change soon and batteries will be operational, but there has been no word yet about when this will affect textiles too.

What will textile producers have to do in future?

Once the registry is able to take textiles DPPs (we expect this will be next year), the relevant brand or importer will need to be verified with a qualified electronic seal or signature, then register each textile DPP.

For brands, importers, etc

If you're the one placing the product on the EU market - which, for most AWARE customers, means the brand - you will have to get verified yourself. 

That means your own legal representative signs or seals a Commission-generated declaration using a qualified electronic signature obtained from a recognised trust service provider, done directly with the Commission's registry. 

AWARE™ can then officially build your DPPs, host your data, and register it in the registry on your behalf. 

For organisations in Textiles today this is not yet necessary but will be in the future. Get in touch if you have questions or if you want to be notified when it is required.  

For organisations based outside the EU - manufacturers, producers, etc

If a separate EU-based importer or brand brings your product to market - which is the most common arrangement for users of AWARE™ - that EU entity is the one who needs to get verified with the registry, not the producer. The manufacturer has no direct obligation under this Regulation. However, of course it is just good business to ensure the data you provide as a producer is what is required in a DPP. 

If there's no separate EU importer and you place the product on the EU market yourself, the Regulation does allow for that and you, as a non-EU manufacturer will have to get verified using a qualified electronic signature or seal from a recognised trust service provider. 

Again, importantly, for organisations in Textiles today this is not yet necessary. Get in touch if you have questions or if you want to be notified when it is required.  

What's the "testing environment"?

Alongside the real registry, the Commission also switched on a separate testing environment. It's a sandbox, entirely apart from the live registry, with its own web address and its own login. Organisations can use it to practise enrolling and registering without any of it counting as official - nothing entered there is real, and test data can be cleared at any time. 

It’s mostly for organisations like AWARE™ to be able to design APIs around. We'll use the testing environment once there's an actual reason to - once textiles have a product group and something real to register.

If you've seen this mentioned and wondered whether it means you need to act now: you don't. There's nothing meaningful to test yet since no textiles product group exists in the live registry or the test one. 

You can probably stop reading here, the rest of this article is a summary of the research we did to write what you have already read. 

Full technical breakdown: Implementing Regulation (EU) 2026/1778

Adopted 16 July 2026, published in the OJ 17 July 2026, in force from 6 August 2026. Binding and directly applicable across the EU. 

Article-by-article summary

Article 1 - Subject matter and scope Sets implementation arrangements for the registry established under the Ecodesign Regulation¹. Applies to operators placing on the market: products under future ESPR delegated acts, batteries¹¹, construction products¹², toys¹³, detergents and surfactants¹⁴, and any other product a future act brings into scope. 

Lists the topics covered: access management, verification, technical setup (semantic repository, log system, software release management), registering and storing unique identifiers and commodity codes, granularity, DPP statuses, traceability data, update/deletion, personal data, anti-fraud, technical audits, availability.

Article 2 - Definitions Defines registry-specific terms: login credentials, authentication token, identity verification process, verified economic operator, value chain actor (repairer, refurbisher, remanufacturer, recycler given as examples), verified value chain actor, semantic repository, semantic interoperability, controlled vocabulary, semantic specification, semantic conformity, data model, log system, data exchange model, hash of the DPP version, massive data download. 

Imports further definitions from the Ecodesign Regulation¹, eIDAS², the Open Data Directive⁵, Regulation 2018/1725³, NIS2⁶, the Market Surveillance Regulation⁷, and the Union Customs Code⁸.

Article 3 - Structure of the registry The registry consists of: a secure-UI website, an API, a verification platform, a unique registration identifier scheme, a storage component for unique identifiers and commodity codes, a list of verified DPP service providers, a semantic repository, a log system, and identification/authorisation schemes.

Article 4 - Verification requirements for economic operators Natural persons acting as sole traders prove identity with a QES from a QTSP², or an eID at assurance level "high," or an equivalent e-attestation. Legal persons use a QSeal from a QTSP² instead. Verified status grants registry access and lasts until the e-ID means expire, capped at 3 years, after which re-verification is required. Prior equivalent verification in another EU information system exempts an operator from re-verifying.

Article 5 - Verification requirements for value chain actors Mirrors Article 4 exactly, for value chain actors instead of economic operators. Same 3-year cap, same re-verification trigger, same exemption for equivalent prior verification.

Article 6 - Management of verified EO/VCA user profile Where Union law provides for it, verified economic operators and value chain actors may delegate access rights to third parties acting on their behalf. Each EO/VCA manages its own verification process and keeps its profile data current.

Article 6a - Transfer of registered digital product passports Registered DPPs may be transferred to another verified economic operator or value chain actor, which then takes over the related obligations from the transfer date.

Article 7 - National authorities Member States must appoint a single national administrator by 18 February 2027 as the Commission's contact point for that state's registry access rights. The administrator may delegate access to national authorities, under full Member State responsibility.

Article 8 - Registration of a digital product passport The relevant verified economic operator or actor registers a DPP at the granularity level (model/batch/item) set in the applicable delegated act or Union law. Where the applicable Union law permits it, a third party may register on the operator's behalf once verified under Article 19(4).

Where a product falls under multiple granularity rules, it's registered at the most granular level required. Item-level registrations carry batch and model identifiers where these exist; batch-level registrations carry the model identifier. Registration is via the secure UI or API. On submission, the Commission automatically checks semantic conformity, data coherence, granularity, commodity code validity, and the DPP service provider backup link. 

A successful check generates a unique registration identifier (URI), and the Commission stores the unique identifiers, commodity code, service provider reference, and registrant information.

Article 9 - Proof of registration An economic operator, or a third party acting on its behalf, can generate proof of registration at any time - a downloadable document containing the unique product identifier, commodity code, the verified operator's identity, a Commission e-timestamp, and a hash of the DPP version. Sealed by the Commission, it remains available for 90 calendar days and can be regenerated.

Article 10 - Registration data management Every change to registration data is logged and versioned with a Commission timestamp. Registration data is deleted 10 years after registration by default, unless other Union law sets a different period.

Article 11 - Data models Data models follow the applicable delegated acts or other Union law where these exist, may build on existing Union semantic assets, and are structured per the semantic repository (Article 12). Data models are versioned.

Article 12 - Semantic repository The Commission establishes a semantic repository under Regulation 2024/903⁹, containing the meaning of DPP data attributes, data models per product group, associated metadata (DCAT-AP¹⁰ compliant), the meaning of roles defined in Union law, and multilingual labels for mandatory attributes. Includes a search service and publicly documented, free, machine-readable APIs.

Article 13 - Technical support Helpdesk operating year-round, 08:00–20:00 Brussels time, with an automated 24/7 tool due by February 2029.

Article 14 - Log system Logs access/authentication events, data modifications, administrative actions, and data exchange. Retention: 6 months for access/authentication, 5 years for administrative and data exchange logs, duration of registration for data modification logs.

Article 15 - Maintenance and registry availability Available at all times except planned maintenance (advance notice given), with the Commission able to suspend access without notice for a malfunction, cyberattack, or urgent security need.

Article 16 - Information system security and technical audits The Commission runs technical audits and random checks, and takes measures to prevent unauthorised access and data breaches.

Article 17 - Inappropriate or fraudulent use The Commission acts against fraudulent activity, including "massive data download." Users must report suspected malicious behaviour immediately.

Article 18 - Personal data The Commission stores names, authentication credentials, postal address, email, and identity-relevant document metadata. For natural persons, also a national identifier (passport, national ID, eID, tax ID, or equivalent). Processed under Regulation 2018/1725³.

Article 19 - Responsibilities of the verified economic operator Must keep registration data accurate and current, and secure its own IT systems and credentials. Where it authorises a third party to register on its behalf, that third party must itself be verified under Article 5 — the economic operator remains fully responsible regardless.

Article 20 - Responsibilities of verified value chain actors Mirrors Article 19 for value chain actors: remains responsible even where a third party acts on its behalf, and must secure its own IT systems and credentials.

Article 21 - Responsibilities of the Commission Owns and manages the registry's full lifecycle, and may transmit registry data to Commission services or national authorities for market surveillance, consumer protection, or customs compliance.

Article 22 - Responsibilities of the Member States Own their national interconnection components, and act as controllers under GDPR⁴ for their own processing of registry data.

Article 23 - Monitoring and evaluation The Commission evaluates this Regulation by end 2032, and every six years thereafter.

Article 24 - Entry into force 20 days after OJ publication — 6 August 2026.

Part 2 - What this means for AWARE™

• The registration/verification split holds exactly as we expected. AWARE™ can register DPPs on a customer's behalf once verified as a value chain actor under Article 5. 
• AWARE™ cannot perform or stand in for the customer's own identity verification under Article 4 - that stays with the economic operator, and Article 19(4) makes the economic operator "fully responsible" regardless of who does the registering.
• Proof of registration (Article 9) is a plausible product feature — since a third party that performed the registration can also generate the proof, this could sit inside the AWARE™ platform rather than customers fetching it from the EU registry UI directly.
• The 2032 evaluation clause signals this framework is meant to be stable for years, useful context for how much platform investment against this spec is justified now versus waiting for delegated acts.

Part 3 - Open questions

1. Article 3(f)'s "list of verified digital product passport service providers" is never operationalised anywhere in this Regulation. Unclear whether AWARE™ verifies as a plain value chain actor and that's the end of it, or whether a separate listing process still needs defining.
2. Article 8's delegation right is conditional on "where provided by Union law." Whether AWARE™'s right to register on behalf of textile customers is actually "provided by Union law" may depend on the textiles delegated act itself, which hasn't been published.
3. Article 4/5’s "equivalent" prior verification exemption references integration with "another Union information system" (EPREL given as the example). Unclear whether this could ever extend to a private verification process AWARE runs itself.

References

1. Regulation (EU) 2024/1781 — Ecodesign for Sustainable Products Regulation (ESPR)
2. Regulation (EU) No 910/2014 — eIDAS Regulation
3. Regulation (EU) 2018/1725 — data protection for EU institutions and bodies
4. Regulation (EU) 2016/679 — General Data Protection Regulation (GDPR)
5. Directive (EU) 2019/1024 — Open Data Directive
6. Directive (EU) 2022/2555 — NIS2 Directive
7. Regulation (EU) 2019/1020 — Market Surveillance Regulation
8. Regulation (EU) No 952/2013 — Union Customs Code
9. Regulation (EU) 2024/903 — Interoperable Europe Regulation
10. DCAT-AP — Data Catalogue Application Profile for data portals in Europe
11. Regulation (EU) 2023/1542 — Batteries and Waste Batteries Regulation
12. Regulation (EU) 2024/3110 — Construction Products Regulation
13. Regulation (EU) 2025/2509 — Toy Safety Regulation
14. Regulation (EU) 2026/405 — Detergents and Surfactants Regulation

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- Rhys，AWARE™