DPP 注册系统实施条例 (EU) 2026/1778:序言14、16 与第3—10、15—16、19—21条
2026-11-12 · KIRIN DPP 知识库 · 依据公开法规整理
=== Recital 14 ===
(14) Registration of the digital product passport in the registry should be carried out by the economic operator at the level of granularity set out in the applicable Union law, namely at model, batch or item level. In order to ensure full functionality of the registry, in particular for competent national authorities and customs authorities, where a digital product passport is created at item level, the corresponding batch and model identifiers should also be registered together with that digital product passport in the registry, provided that batch and model design exist for the product concerned. For products that are unique by nature, including handmade goods, no batch and model identifiers are required. The same rule applies for digital product passports issued at batch level, where a model identifier is required upon registration. In that context, the batch identifier and the model identifier should represent the higher-level grouping of the product concerned. Those identifiers should be issued by the economic operator in order to enable the competent national authorities to trace products belonging to a specific batch or model registered in the digital product passport registry. Where the same product is subject to several Union rules requiring registration of its digital product passport at different levels of granularity (model, batch or item), the digital product passport should be registered at the most granular of those levels.
=== Recital 16 ===
(16) To ensure that only complete and valid digital product passports are registered, the Commission should, as the owner and manager of the registry in accordance with Article 13(1) of Regulation (EU) 2024/1781, perform an automatic verification of the submitted data. It should verify at least the data structure and the level of granularity (model, batch or item) of the digital product passport for that relevant product in accordance with the applicable Union rules. Where relevant, the product commodity codes and the link to the back-up hosted by a digital product passport service provider should also be subject to verification. The verification of the substantive correctness of the data registered remains a task for the market surveillance authorities under the applicable Union rules. Accordingly, the automated verifications should not be deemed to constitute proof of compliance with the requirements of the Union rules applicable to the product, including with market surveillance rules.
=== Article 3 ===
Article 3 Structure of the registry The registry shall consist of the following: (a) a website providing a secure user interface for economic operators, value chain actors, competent national authorities and customs authorities to access the registry; (b) an API for registering the digital product passport and receiving information from the registry; (c) a verification platform to confirm and verify the existence and completeness of the digital product passports; (d) a scheme for generating unique registration identifiers; (e) a storage component for at least the unique identifiers and the commodity codes for products intended to be placed under the customs procedure ‘release for free circulation’; (f) a list of verified digital product passport service providers registered in the registry; (g) a semantic repository; (h) a log system; (i) identification and authorisation schemes for registry users.
=== Article 4 ===
Article 4 Verification requirements for economic operators 1. Economic operators that are natural persons acting as sole traders shall be qualified as ‘verified economic operators’ if one of the following conditions is satisfied: (a) where required to be established in the Union, they submit evidence of their identity by means of a qualified electronic signature supported by a qualified certificate for electronic signatures in accordance with Regulation (EU) No 910/2014; or they submit evidence of their identity by means of an electronic identification means that meets the requirements of Regulation (EU) No 910/2014 with regard to the assurance levels ‘high’, or an electronic attestation of attributes issued under Union law that enables the identification of the economic operator; (b) where not required to be established in the Union, they submit evidence of their identity by means of a qualified electronic signature supported by a qualified certificate for electronic signatures in accordance with Regulation (EU) No 910/2014, or an electronic attestation of attributes issued under Union law that enables the identification of the economic operator. 2. Economic operators acting as legal persons shall be qualified as ‘verified economic operators’ if one of the following conditions is satisfied: (a) where required to be established in the Union, they submit evidence of their identity and of their establishment by means of a qualified electronic seal supported by a qualified certificate for electronic seal, issued by a qualified trust service provider pursuant to Regulation (EU) No 910/2014; or after submitting evidence of their identity and of their establishment by means of a qualified electronic attestation of attributes issued under Union law that enables the identification of the economic operator; (b) where not required to be established in the Union, they submit evidence of their identity and, where applicable, of their establishment by means of a qualified electronic seal supported by a qualified certificate for electronic seal, issued by a qualified trust service provider pursuant to Regulation (EU) No 910/2014, or an electronic attestation of attributes issued under Union law that enables the identification of the economic operator. 3. Without prejudice to other Union law, access to the digital product passport registry shall be granted to verified economic operators for the purpose of registering digital product passports. . 4. Economic operators shall retain the status as verified economic operators until their electronic identification means expire but no longer than three years from the date of verification in accordance with paragraph 1 or 2. Once such means expire or the three-year period has expired, whichever occurs first, economic operators shall no longer be able to register new digital product passports in the registry or modify any data referred to in Article 8. They may do so only if they successfully repeat the identity verification process in accordance with paragraph 1 or 2. The status of the digital product passport in the registry shall be updated accordingly. 5. Without prejudice to paragraph 4, where the digital product passport registry is integrated with another Union information system with an equivalent or identical identity verification process, the economic operator already registered in that information system is not required to undergo a new identity verification process in the digital product passport registry.
=== Article 5 ===
Article 5 Verification requirements for value chain actors 1. A value chain actor who is a natural person acting as a sole trader shall obtain a verified status in the registry if one of the two following conditions is fulfilled: (a) where required to be established in the Union, they submit evidence of their identity by means of a qualified electronic signature supported by a qualified certificate for electronic signatures in accordance with Regulation (EU) No 910/2014; or they submit evidence of their identity by means of an electronic identification means that meets the requirements of Regulation (EU) No 910/2014 with regard to the assurance levels ‘high’, or an electronic attestation of attributes issued under Union law that enables the identification of the value chain actor; (b) where not required to be established in the Union, they submit evidence of their identity by means of a qualified electronic signature supported by a qualified certificate for electronic signatures in accordance with Regulation (EU) No 910/2014, or an electronic attestation of attributes issued under Union law that enables the identification of the value chain actor. 2. A value chain actor acting as a legal person shall obtain a verified status in the registry if one of the following conditions is satisfied: (a) where required to be established in the Union, they submit evidence of their identity and of their establishment by means of a qualified electronic seal supported by a qualified certificate for electronic seal, issued by a qualified trust service provider pursuant to Regulation (EU) No 910/2014; or they submit evidence of their identity and of their establishment by means of a qualified electronic attestation of attributes issued under Union law that enables the identification of the value chain actor; (b) where not required to be established in the Union, they submit evidence of their identity and, where applicable, of their establishment by means of a qualified electronic seal supported by a qualified certificate for electronic seal, issued by a qualified trust service provider pursuant to Regulation (EU) No 910/2014, or an electronic attestation of attributes issued under Union law that enables the identification of the value chain actor. 3. Only verified value chain actors shall have access to the registry and may perform, where specified in the relevant Union law, actions in the registry. 4. A value chain actor shall retain the status as verified until their electronic identification means expire and in any event no longer than three years from the date of verification in accordance with paragraph 1 or 2. Once such means have expired or once the three-year period has expired, whichever occurs first, these actors shall no longer be able to perform registrations or modify any data in the registry. They may do so only if they successfully repeat the identity verification process in accordance with paragraph 1 or 2. 5. Without prejudice to paragraph 4, where the digital product passport registry is integrated with another Union information system with an equivalent or identical identity verification process, the value chain actor already registered in that information system is not required to undergo a new identity verification process in the digital product passport registry.
=== Article 6 ===
Article 6 Management of verified economic operator and verified value chain actor user profile 1. Where provided by Union law, verified economic operators and verified value chain actors may delegate access rights to third party users acting on their behalf. 2. Any personal data which is entered as part of the user profile of a verified economic operator or a verified value chain actor shall be processed in accordance with Regulation (EU) 2018/1725. 3. Each economic operator and each value chain actor shall be responsible for managing their electronic verification process in accordance with Articles 4 and 5, respectively. 4. The verified economic operator and verified value chain actor shall be responsible for updating their data in the event of any relevant change.
=== Article 7 ===
Article 7 National authorities 1. At the latest by 18 February 2027, Member States shall appoint a designated national administrator who shall act as the single official contact point for the Commission for the purposes of managing registry access rights for that Member State. 2. Member States shall communicate to the Commission the name and contact details of their respective designated national administrator and shall notify the Commission of any subsequent changes with regard to their designated national administrator. 3. The designated national administrator may delegate registry access rights to relevant national authorities within its Member State. Such delegation shall be carried out under the full responsibility of the Member State and in a way that ensures the security, integrity and confidentiality of the registry data accessed in accordance with this Regulation. 4. National authorities which have been granted access by their designated national administrator may delegate and manage registry access rights further within their respective authority. 5. Personal data contained in the user profiles and user accounts of the competent national authorities and customs authorities shall be processed by the Commission in its capacity as controller in accordance with Regulation (EU) 2018/1725.
=== Article 8 ===
Article 8 Registration of a digital product passport 1. For products referred to in Article 1(1), point (a), a digital product passport shall be registered by a verified economic operator placing the product on the market or putting it into service at the level specified in the applicable delegated acts (model, batch or item level) adopted pursuant to Article 4 of Regulation (EU) 2024/1781. 2. For products referred to in Article 1(1), points (b) to (f), a digital product passport shall be registered by the relevant actor at the level (model, batch or item level) specified in the relevant Union law. Where Union law provides for a third party to perform actions in the registry on behalf of the actors referred to in the first or second sub-paragraphs, such third party, once verified according to Article 19(4), will be allowed to perform registration actions in the registry. 3. Where the same product is subject to different Union rules requiring the registration of its digital product passport at different levels of granularity, the digital product passport shall be registered for that product at the most granular level required by the relevant Union legislation. 4. Where the digital product passport is created at item level, in accordance with paragraph 1, both batch and model identifiers shall be linked to that digital product passport where batch and model design exist for the product. 5. Where the digital product passport is created at batch level, in accordance with paragraph 1, the model identifier shall be linked to that digital product passport where model design exists for the product. 6. The relevant actor referred to in paragraph 1 shall register a digital product passport either through the secure user interface of the registry as provided for in Article 3, point (a), or through the API as provided for in Article 3, point (b). 7. Upon submission for registration, the Commission shall read the digital product passport content and automatically confirm: (a) the semantic conformity of the data provided in the digital product passport, as provided for in the applicable delegated acts adopted pursuant to Article 4 of Regulation (EU) 2024/1781 or in the applicable delegated acts adopted pursuant to Article 77 of Regulation (EU) 2023/1542, or under other Union law providing for the data about the digital product passport to be registered in the digital product passport registry; (b) where relevant, coherence of the mandatory data to be uploaded in the registry against the value of the data provided in the digital product passport; (c) the conformity of the digital product passport with the granularity level (model, batch or item) as provided for in the applicable delegated acts adopted pursuant to Article 4 of Regulation (EU) 2024/1781 or in the applicable delegated acts adopted pursuant to Article 77 of Regulation (EU) 2023/1542, or under other Union law providing for a specific level for the digital product passport to be registered in the registry; (d) where relevant, the validity of the commodity code of the product in relation to the permitted ranges for this product group; (e) where relevant, the link to the back-up hosted by a digital product passport service provider. 8. Following a successful verification in accordance with paragraph 6, the registry shall generate and store a unique and persistent registration identifier as part of the registration data. 9. Additionally, the Commission shall store in the registry the following information as part of the registration data: (a) where relevant, the unique identifiers; (b) where relevant, the commodity code of the product; (c) where relevant, reference to the digital product passport service provider; (d) registrant information, including date and time of the registration and the integrity of the digital product passport as part of the evidence of the registration event. 10. Upon successful submission by the relevant actor as referred to in paragraph 1, of the data in the registry, the Commission shall automatically communicate to that relevant actor the unique registration identifier for that specific product generated in accordance with paragraph 9. The unique registration identifier shall be communicated through the user interface or the API response, depending on the service used by the relevant actor during registration.
=== Article 9 ===
Article 9 Proof of registration 1. An economic operator or, where relevant, a third party on behalf of the economic operator, that has registered a digital product passport in the registry in accordance with Article 8 shall be able to generate, at any given time, proof of registration for one or more digital product passports for which that economic operator is responsible. 2. The proof of registration shall serve as evidence, including vis-à-vis third parties, that the registration obligation for that digital product passport has been fulfilled. It shall be generated as a secure electronic document that can be downloaded by the actor that registered the digital product passport from the registry, and shall contain at least the following data: (a) the unique product identifier; (b) where relevant, the commodity code as referred to in Article 8(9), point (b); (c) the name and identity of the verified economic operator responsible for the registration as referred to in Article 8(9), point (d); (d) the date and time of the registration for the latest version of the digital product passport for which the proof is generated in accordance with Article 8(9), point (d), which is validated by an electronic time stamp of the Commission; (e) a hash of the version of the digital product passport for which the proof is generated. 3. Proof of registration shall be guaranteed by means of a qualified electronic seal as provided for in Article 38 of Regulation (EU) No 910/2014 and shall include the electronic time stamp of the Commission referred to in paragraph 2, point (d). 4. The Commission shall make available in the registry to the requesting verified economic operator the proof of registration through the registry’s secure user interface or through the API, depending on the service chosen by the economic operator. That proof shall remain available for a period of 90 calendar days from the date of its generation.
=== Article 10 ===
Article 10 Registration data management 1. Any change to the digital product passport registration data, including its creation, modification and deletion, shall be logged in the log system of the registry in accordance with Article 14 and reflected in the status of the registration. 2. The registry shall support the versioning of the registered data, and storea timestamp of the Commission for each update. 3. Where Union law does not provide for a specific duration of availability of the digital product passport, digital product passport registration data, as referred to in Article 8(7) and (8), shall be deleted automatically from the registry 10 years after registration. Where Union law provides for a specific duration of availability of the digital product passport, the retention period of such data shall be aligned with the period of availability of the digital product passport. 4. Registry users shall have the right to request deletion of their respective account if they are no longer responsible for activities related to the registry.
=== Article 15 ===
Article 15 Maintenance and registry availability 1. The Commission shall make available on its website guidelines and instructions on how to register and manage data in the registry. 2. The registry shall be accessible at all times, except during necessary maintenance activities such as the deployment of new software releases, and without prejudice to paragraph 3. In those instances, the Commission shall issue an advance notice of inaccessibility on the public website of the registry. 3. The Commission may suspend the availability of the registry, without prior notice, where it is necessary due to a malfunction, a cyber-attack or a compelling urgent security need, until the issue is resolved. 4. Where registration is prevented by the temporary unavailability or malfunctioning of the registry, the Commission shall record the date and time of unavailability and make such information available to economic operators, value chain actors, competent national authorities and customs authorities upon request for no less than five years.
=== Article 16 ===
Article 16 Information system security and technical audits 1. The Commission shall ensure the security of the registry and its components as referred to in Article 3. To that end, the Commission may conduct technical audits and random checks on the components of the registry. 2. For the purposes of paragraph 1, the Commission shall take the necessary measures in order to: (a) prevent any unauthorised access to the registry; (b) prevent any unauthorised processing of registry data; (c) detect any unauthorised activities in the registry; (d) prevent any data breaches of the registry; (e) ensure that security events are logged in accordance with the information technology security standards applied by the Commission.
=== Article 19 ===
Article 19 Responsibilities of the verified economic operator 1. A verified economic operator registering a digital product passport shall provide the Commission as manager of the registry with all information necessary for the registration, as provided for in Article 8. The verified economic operator shall be responsible for the accuracy and completeness of the information submitted at the time of registration. 2. The verified economic operator shall ensure that the information stored in the registry of the digital product passport is kept accurate, complete and up to date at all times. 3. The verified economic operator shall be responsible for implementing appropriate technical and organisational security measures for its IT systems and credentials used to access the registry, to prevent unauthorised access to or modification of registration data through its IT system. 4. Where a verified economic operator authorises a third party to perform registration actions in the registry on its behalf, the third party actor needs to follow the verification process in accordance with Article 5. The verified economic operator shall remain fully responsible for compliance with the obligations set out in this Regulation. 5. Each verified economic operator shall be responsible for the data it submits to the Commission as manager of the registry and shall be considered as the controller of the data it submits.
=== Article 20 ===
Article 20 Responsibilities of verified value chain actors 1. Where a verified value chain actor authorises a third party to act on its behalf, the verified value chain actor shall remain responsible for compliance with the obligations set out in this Regulation. 2. A verified value chain actor shall be responsible for implementing appropriate technical and organisational security measures with regard to its IT systems and credentials that are used to access the registry, in order to prevent unauthorised access to or modification of registration data through its IT system. 3. Where Union law provides for value chain actors to upload any information to the digital product passport registry, each verified value chain actor shall be responsible for the data it submits to the Commission as manager of the registry and shall be considered as the controller of the data it submits.
=== Article 21 ===
Article 21 Responsibilities of the Commission 1. The Commission shall ensure that the data stored in the registry is processed securely and in compliance with Union law, including applicable rules on the protection of personal data. 2. The Commission shall be the owner of the registry and responsible for its management, including its development, availability, monitoring, updating, maintenance and hosting. 3. The data that the Commission can obtain from the registry may be transmitted to the relevant services within the Commission or to competent national authorities for the purposes of carrying out measures required under other Union legislative acts, including market surveillance, consumer protection and customs compliance.
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