compliance

DPP as Customs Tool: What the Commission Confirmed in 2026

The European Commission confirmed DPP integration into EU customs enforcement. What this means for importers, compliance teams, and border checks.

3/27/2026 · 7 min read · InfoDPP

🔄 Update (26 March 2026): The European Parliament and Council reached a provisional political agreement on the most comprehensive EU Customs Reform since 1968. The agreement establishes an EU Customs Data Hub (available for optional use by 2031 and mandatory by 2034), a new EU Customs Authority in Lille, and introduces a per-parcel handling fee for goods entering the EU from non-EU sellers. This political agreement significantly reinforces the direction of DPP-based customs enforcement described in this article. Source: European Parliament press release

Registry update, 22 July 2026: the Commission describes the production DPP Registry as operational, with registration available through a secure interface or API and a separate testing environment. This does not activate customs checks. The Registry-to-EU-Single-Window interconnection remains due by 6 August 2030, and product-specific DPP obligations still determine what customs can check.

Status, 20 September 2026: Parliament approved the customs reform at second reading and the final act was signed on 16 September. OEIL lists procedure 2023/0156(COD) as completed, awaiting publication in the Official Journal. This does not bring forward DPP obligations or the Registry-to-customs interconnection deadline of 6 August 2030. European Parliament procedure.

What the Commission Confirmed to the Parliament

In a written answer published on 17 March 2026 (E-005012/2025), the European Commission confirmed to the European Parliament that EU customs systems are being built to access relevant regulatory information such as DPP data. The answer addressed growing concerns about product non-compliance across EU borders, particularly in e-commerce channels.

The key data point: over 50% of products sampled from online imports were found to be non-compliant with applicable EU product rules. The Commission acknowledged this as a systemic enforcement gap and presented the DPP as one tool in a broader enforcement response. Importantly, this non-compliance rate describes the market before DPP border checks are operational.

Battery passports and customs declarations

For products covered by ESPR, Article 15 provides for the unique registration identifier to be supplied when the product is declared for release for free circulation. The product obligation and the technical customs connection must both be checked before treating this as an operational procedure.

Battery passports follow a different rule. The September 2026 FAQ for batteries, question 4.1, explains that the passport must be registered in the EU DPP Registry, but its registration identifier does not have to be entered in the electronic customs declaration. This exception concerns the regime under Regulation (EU) 2023/1542. It does not remove the battery passport, registration or other import obligations.

An importer should therefore identify the applicable product law before adding a DPP identifier to its customs process. The battery clarification is not evidence that the same exception applies to toys, detergents or future ESPR product groups.

What Was Specifically Confirmed

The parliamentary answer described several areas of enforcement work:

1. DPP data in the EU Single Window

The Commission confirmed that DPP data will be accessible through the EU Single Window Environment for Customs, which connects customs systems with Union non-customs formalities. Regulation 2026/1778 now makes the Registry requirements more specific: registrations include a product identifier and, where relevant to customs and release for free circulation, a commodity code, and receive a unique registration identifier. ESPR Article 15 sets a deadline of 6 August 2030 for the technical interconnection; the detailed border workflow remains to be published.

2. Market surveillance and customs cooperation

The answer reaffirmed the strengthening of the link between market surveillance authorities and customs authorities. Under ESPR, market surveillance can request DPP data to verify compliance. The customs integration extends this check to the border itself, before products reach the internal market.

3. E-commerce enforcement as a priority

The Commission explicitly flagged online sales channels as a priority enforcement gap. Products sold through online marketplaces often bypass traditional import routes and compliance checks. DPP-linked customs verification is framed as one response within a wider enforcement package for this channel.

What This Does Not Mean

It is important to separate confirmed direction from operational detail:

this does not mean customs officers will scan every product’s QR code at the border tomorrow
the Registry-to-Single-Window technical interconnection remains to be built; ESPR sets 6 August 2030 as the statutory operational deadline
the exact triggering conditions for border DPP checks (random, risk-based, complaint-driven) are not yet published
this applies to products subject to an applicable DPP mandate: either an ESPR delegated act or a standalone regulation (Battery Regulation (EU) 2023/1542, Toy Safety Regulation (EU) 2025/2509, Detergents Regulation (EU) 2026/405), not to all imported goods

Why This Matters for Importers

For companies importing products into the EU, the link between customs systems and DPPs raises additional compliance risks:

Products without valid DPP data may be flagged at the border

If a product should have a DPP under an applicable act, an ESPR delegated act or a standalone regulation (batteries, toys, detergents), and the applicable customs check finds missing or inconsistent information, release may be affected once the product rule and technical connection apply. As of July 2026, the standalone regulations are already in force (Battery Regulation from 2023 with DPP obligations from 18 February 2027, Toy Safety Regulation from 1 January 2026 with DPP from 1 August 2030, Detergents Regulation with DPP from 23 September 2029), while no ESPR delegated acts have yet mandated a DPP. Customs integration will therefore support enforcement as the relevant requirements take effect for each category.

Importers have independent verification duties

Manufacturers retain their own creation and accuracy duties. Importers also have independent verification obligations under ESPR and the parallel sector provisions: they cannot rely only on a supplier’s assurance where the applicable law requires them to check the DPP and carrier before placing the product on the market. A border problem will therefore affect the importer operationally even though it does not erase the manufacturer’s responsibility.

For a full guide on importer obligations, see Importing Products into the EU: DPP Responsibilities.

Online sellers should prepare for closer scrutiny

The Commission identifies online imports as a priority for controls. More than 50% of the products examined in the cited joint control action were noncompliant. Sellers on EU marketplaces who import products from manufacturers outside the EU should therefore prepare for closer scrutiny. Controls are not limited to online sales, and a DPP alone will not resolve noncompliance.

What Should Companies Do Now

1. Treat DPP as a border-readiness issue, not just a product-readiness issue

Prepare the DPP data alongside the other documents needed for imports. Include your customs broker, freight forwarder and trade compliance team in this work. They will need the data when passports become subject to the relevant customs checks.

2. Verify DPP data before shipment, not after arrival

Once the relevant customs checks cover DPPs, missing data may delay deliveries, increase storage costs or lead to refusal of release. A market surveillance fine may also apply. Check the data before shipment.

3. Monitor which product categories are covered

Not all products require a DPP at once. Check the applicable delegated act or standalone sector regulation, its application date and the relevant customs provisions. The industry pages provide a starting point.

4. Prepare for risk-based checks on e-commerce imports

If you sell via online marketplaces and your products are imported from outside the EU, prepare for closer scrutiny of product documentation, including DPP data when the relevant obligations apply.

Official Sources

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