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No DPP Registry Is Authoritative Yet — And That's the Problem

The EU Common Information Repository (EU CIR) is still in pilot phase. GS1, IDTA, and CIRPASS-2 each have competing registry models. Where should importers register their DPPs today?

9 min read

If you have been trying to understand where to register your Digital Product Passports, you have probably encountered a confusing landscape: the EU Common Information Repository (EU CIR), GS1 Digital Link, IDTA Asset Administration Shell, CIRPASS-2 interoperability framework, and half a dozen national registry initiatives. Each claims to be the right answer. None is yet the authoritative one.

This matters practically because the DPP you create today needs to be discoverable by EU customs and market surveillance authorities in 2027. If you register in the wrong place — or only one place — you may need to redo the work.

The EU CIR: Still a Pilot

The EU Common Information Repository is the Commission's preferred long-term registry model. It provides a central index of DPP identifiers, so any ESPR-compliant resolver can locate the authoritative data endpoint for a given product. But as of mid-2025, the CIR is still running in pilot phase with selected industry partners. Full production operation is expected in 2026, concurrent with the first battery DPP mandates.

What this means: you can register with the EU CIR now (if you are a pilot participant or use a platform that is), but you cannot rely on CIR registration alone to satisfy the full ESPR discovery requirement. The CIR may also change its API schema between pilot and production.

The CIRPASS-2 registration format — which PassportLab implements — uses POST /metadata/v1/registerDPP with fields including upi (unique product identifier), reoId (economic operator EORI), liveURL, backupURL, granularityLevel, and facilitiesId. This format is designed to be forward-compatible with the expected EU CIR production schema.

GS1 Digital Link is not a registry — it is a URL syntax standard that encodes GTIN, serial number, and other GS1 identifiers into a resolvable URL. The format /01/{gtin}/21/{serial} is already widely adopted in retail and logistics, and ESPR delegated acts reference it explicitly for physical product identification.

GS1 Germany (a PassportLab partner) operates a resolver infrastructure that can redirect GS1 Digital Link URLs to any registered endpoint. If your product has a GTIN, registering with GS1 is effectively mandatory — not because the regulation says so, but because supply chain partners (retailers, logistics providers, customs pre-filing systems) increasingly expect it.

GS1 Digital Link is the best-supported path to physical product identification today. It is not, however, a full DPP registry. It does not store your DPP data — it resolves to where your data is hosted.

IDTA AAS: The Industrial Track

The Industrial Digital Twin Association (IDTA) Asset Administration Shell format is primarily used in industrial supply chains — machinery, automotive, industrial electronics. If you supply Tier 1 manufacturers in Germany, France, or Italy, there is a growing expectation that your product DPP will be expressible as an AAS submodel.

The ESPR regulations do not mandate AAS format, but the IDTA has working groups aligning AAS submodels with ESPR data requirements. For industrial product manufacturers, AAS compatibility will likely become a commercial requirement from large buyers before it becomes a regulatory one.

PassportLab generates AAS-compatible JSON at GET /public/dpp/{code}/aas.json covering Nameplate, TechnicalData, CarbonFootprint, Circularity, and EnergyConsumption submodels. This is available today for products where the data fields are populated.

The Practical Answer: Multi-Registry Resilience

Given the fragmented registry landscape, the pragmatic approach is not to pick one and hope it wins. It is to structure your DPP so it can be registered in multiple places simultaneously without creating conflicting records.

The key requirements for multi-registry registration:

  1. Stable canonical URL: your DPP must have a URL that will not change. This is your primary endpoint. Every registry points here.
  2. Backup URL: a secondary endpoint that serves identical data if the primary is unreachable. Required by CIRPASS-2, recommended by ESPR.
  3. GS1 Digital Link: if your product has a GTIN, register the resolver redirect. This is the lowest friction path for supply chain discovery.
  4. EU CIR: register as soon as the production API is stable, using the CIRPASS-2 format. If you use a platform that already has EU CIR pilot access, register now.
  5. AAS endpoint: if your supply chain includes industrial buyers, expose the AAS submodels now. Retrofitting this later is expensive.

The question is not "which registry?" — it is "how do I stay registered across all of them as the landscape settles?"


PassportLab registers DPPs with the EU CIR (CIRPASS-2 format), GS1 Digital Link, and generates AAS submodels automatically. See our registry documentation or start with a free DPP.

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