You have an electronic signature. The EU registry wants an electronic seal.

Between your factory and the registry of digital product passports stands one certificate. For most companies it is not the one they already own.

How the registry works is set out in Commission Implementing Regulation (EU) 2026/1778. Article 4 says who may register a passport in it, and the answer is: only a “verified economic operator”. To become one as a legal person, you submit evidence of your identity and of your establishment “by means of a qualified electronic seal supported by a qualified certificate for electronic seal, issued by a qualified trust service provider”.

A seal. Not a signature.

A signature and a seal are two different products

The distinction comes from Regulation (EU) No 910/2014, known as eIDAS. A qualified electronic signature is created by a natural person and carries the legal effect of a handwritten signature. A qualified electronic seal is created by a legal person and attests that data originates from that company and has not been altered since. It is the digital equivalent of the company stamp, not of the manager's signature.

Providers routinely sell both from the same page, under one heading. One provider's own comparison table states it plainly: for the signature the holder is “a natural person representing the legal entity”; the seal is “a legal entity only”. The application, the paperwork and the price all differ.

For a sole trader the rule is different. Article 4(1) asks for a qualified electronic signature, an electronic identification means meeting assurance level “high”, or an electronic attestation of attributes. A seal is asked only of legal persons, because only a legal person can hold one.

What the seal opens, and what happens when it lapses

Article 4(3) gives verified economic operators access to the registry for the purpose of registering passports. Article 4(4) puts a clock on that status: until the electronic identification means expire, and in any event no longer than three years from the date of verification.

If the clock runs out, the passports you have already registered do not disappear. What disappears is the right to register new ones and to modify data, until you complete verification again.

The same article carries a paragraph almost nobody discusses. Paragraph 5 says that where the registry is integrated with another Union information system with an equivalent or identical identity-verification process, an operator already registered there does not go through verification a second time. The regulation names no system. The obvious candidate is EPREL, the energy-label registry, which has run on qualified electronic seals since 2022. Whether it will count, the text does not settle. If you have been through EPREL already, that is a question worth asking before you pay twice.

How to check what you actually hold

Four checks, each of which takes minutes:

• The type. The certificate itself states what it was issued for: an electronic signature or an electronic seal. If it says signature, it is not the instrument Article 4(2) asks a legal person for.
• The holder. If the certificate was issued to a person, it is a signature, even when your company is named in it as the organisation.
• The provider. Every qualified provider in the EU sits on a national trusted list that is public and machine-readable, and every national list feeds the European list of trusted lists. Check there rather than on a sales page. The list also states which services a provider is actually qualified for, which is not always what the sales page implies.
• The expiry. Your verified-operator status falls with the certificate. If it expires in a year, that is also the horizon of your access to the registry.

One clarification that saves money: the provider does not have to be in your own country. The trust-services market in the Union is open, and a seal issued by a qualified provider in any member state is qualified in all the others.

Cost is not the problem

The order of magnitude is tens of euros a year. The Commission's own guidance for the analogous energy-label registry puts such a certificate at “a few tens of euro, to a thousand euro”. One EU provider's public price list, read on 31 August 2026, sits at the bottom of that range: €30.60 including VAT for a one-year certificate and €68.10 for three years.

The paperwork and the lead time are the problem. A certificate for a legal person needs an identity document for the applicant and proof of the company's registration, and where the certificate holder is not the legal representative, documented authority to act for the company. Several providers will not verify that remotely at all. This is not something you arrange on the day you need it.

Not only manufacturers

Article 5 extends the same verification to “value chain actors”: repairers, refurbishers, remanufacturers, recyclers, and digital product passport service providers. Only verified actors have access to the registry and may perform operations in it.

If you plan to hand registration to an outside provider, read Article 6 closely. Paragraph 1 lets a verified operator delegate access rights to third parties acting on its behalf. Paragraph 3 nevertheless leaves each operator responsible for managing its own electronic verification process. Whether a platform may register under its own seal instead of yours is a question on which both answers are being asserted in the market, and the text does not resolve it in terms. Ask in writing before you assume somebody will do it for you.

What you get back

Article 9 describes the proof of registration: a secure electronic document that a verified operator can generate at any time. It carries the product's unique identifier, the commodity code, the name and identity of the responsible verified operator, the date and time of registration validated by a Commission electronic time stamp, and a hash of the passport version.

The proof itself is guaranteed by a qualified electronic seal under Article 38 of Regulation (EU) No 910/2014, and it stays available for 90 calendar days from the moment it is generated.

This is the document your European buyer will ask for to close its own supplier check. A seal goes in, a seal comes out.

When this becomes your problem

Registration is not general across all products. It is triggered by the act covering your product group. The first hard date is for batteries, 18 February 2027. For textiles, furniture and steel no delegated act applies yet, and the Commission's indicative dates are planning rather than law. The full picture by product group moves several times a year.

The registry itself has been running since 20 July 2026, together with a test environment, and Regulation 2026/1778 has been in force since 6 August 2026. The signature-or-seal check can be done today, calmly, with no deadline over your head. If you obtain a seal now and your product group enters scope in three years, you will verify again. The cost is tens of euros. Learning what you actually need happens once.

The cheapest moment to discover that a signature is not a seal is now. The most expensive is the day you file your first registration. Everything else that has changed in the rules we track in chronological order.