Latest Market Alert | 31 July 2026
Executive Summary
The European Commission has launched the operational Digital Product Passport Registry, beginning the practical implementation phase of a major new product-compliance regime affecting businesses selling into the EU.
The Registry went live on 20 July 2026, together with a testing environment and implementation guidance. Economic operators will eventually register unique product identifiers and associated compliance information through the system.
Batteries will be the first major product category subject to mandatory Digital Product Passports.
From 18 February 2027, the requirement is scheduled to apply to relevant electric-vehicle batteries, light-transport batteries and industrial batteries placed on the EU market.
Why it Matters
This changes product compliance from a largely document-based exercise towards structured, traceable digital data throughout the supply chain.
Information may include:
- manufacturer and economic-operator identity;
- technical specifications;
- performance and durability;
- repair and reuse information;
- recycling and sustainability data;
- product identifiers and regulatory metadata.
Customs and market-surveillance authorities will also be able to use the Registry to verify compliance.
UK Impact
UK manufacturers exporting covered products into the EU remain exposed even though Britain is outside the EU.
Businesses supplying batteries, vehicles, storage systems or components should determine who within the contractual chain is responsible for compiling and maintaining the required data.
The obligation rests with the economic operator placing the finished covered battery on the EU market.
Global Impact
The battery regime is likely to provide a model for wider Digital Product Passport requirements.
Iron and steel, construction products and textiles are among sectors identified for future implementation.
This creates long-term implications for manufacturers, importers, distributors and supply-chain data providers worldwide.
Our View
The principal risk is data readiness rather than the passport itself.
Businesses that wait until the legal deadline may discover that essential information sits several tiers down their supply chain and cannot be obtained quickly.
Recommended actions:
- Identify products likely to fall within DPP requirements.
- Assign internal responsibility for compliance data.
- Map information held by suppliers and manufacturers.
- Add data-provision obligations to supplier contracts.
- Test the EU Registry before mandatory deadlines.
- Review responsibility between manufacturer, importer and distributor.
- Preserve records supporting product and sustainability claims.
Risk Indicator: Medium / High
Disclaimer
The information contained within these Market Alerts is provided for general market awareness and informational purposes only. It does not constitute financial, legal, investment, regulatory or insurance advice. Whilst every effort has been made to ensure accuracy at the time of publication using multiple reputable and independently verified sources, geopolitical events, legislation, regulation and market conditions may change rapidly. Readers should obtain appropriate professional advice before acting upon any information contained herein.
Invictus Risk Solutions LLP – Helping organisations stay ahead of emerging risks through informed insight and independent analysis.