Transparency Revolution: Who Must Implement the Digital Product Passport in the EU

Who does what: roles along the supply chain

Role	Creates the DPP?	Specific responsibilities	ESPR Reference
Manufacturer (EU or non-EU)	✅ Yes	Creates the passport, links it to the product via a data carrier, and registers it in the EU registry before placing it on the market	Art. 27
Authorized Representative	On behalf of the manufacturer	Performs tasks assigned by the manufacturer via a written mandate	Art. 28
Importer	✅ Yes, if the manufacturer has not done so	Verifies that the DPP exists and is compliant before placing the good on the market	Art. 29
Distributor	❌ No	Checks that the product is accompanied by the DPP before making it available	Art. 30
Retailer (selling to the end customer)	❌ No	Ensures the DPP is easily accessible to the customer, including in distance selling	Art. 31
Logistics Service Provider	❌ No	Ensures that warehousing and shipping operations do not compromise compliance	Art. 33
Online Marketplace	❌ No	Designs the interface to allow sellers to display the DPP prior to purchase	Art. 35

1. Manufacturers and importers: who creates the passport

The responsibility for preparing the DPP lies with the economic operator who places the product on the EU market or puts it into service.

• Goods produced in the EU → the obligation falls on the manufacturer. - Goods produced outside the EU → The non-EU manufacturer may handle this directly or through an authorized representative; however, the importer is prohibited from placing the product on the market if the passport is missing or non-compliant. In practice, it is often the importer who must coordinate with the foreign supplier to obtain the necessary data.

Furthermore, customs authorities may verify that the product’s Digital Product Passport (DPP) is registered (Art. 15); a missing passport can result in goods being held at the border.

⚠️ Caution: You may be considered a "manufacturer" even if you are not one. Any party that places a product on the market under their own name or trademark (private label), or modifies a product in a way that affects its compliance, assumes the obligations of a manufacturer (Art. 34). The same applies to many remanufacturing and reconditioning activities.

2. Distributors and retailers: obligations regarding accessibility

While distributors and retailers are not responsible for creating the data structure of the passport, they serve as the final link before the product reaches the consumer and are subject to specific obligations:

• verifying, prior to the sale, that the product is accompanied by the required DPP;
• ensuring the passport is easily accessible to the customer, whether in a physical retail store or through distance selling.

To facilitate this, the economic operator who placed the product on the market must provide retailers and marketplaces with a digital copy of the data carrier (e.g., a QR code) or the unique product identifier.

3. Marketplaces and e-commerce

Online platforms must design their interfaces to allow sellers to display the DPP (or a link to it) before the customer completes their purchase. For those selling online, the product page thus becomes an access point to the passport, much like a physical label.

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What compliance entails: operational steps

1. Mapping products and roles

Identify which of your products fall under a group subject to the DPP (Digital Product Passport) and determine your role for each: manufacturer, importer, distributor, or retailer. A single business entity may hold different roles across different product lines.

2. Collecting and managing data

Manufacturers and importers must gather the information required by the relevant delegated act—such as the origin and composition of materials, recycled content, substances of concern, environmental footprint, and instructions for repair, disassembly, and disposal. Much of this data comes from suppliers, so it is advisable to update contracts and specifications now.

3. Linking the passport to the product

The DPP must be associated with the item via a persistent unique identifier and a data carrier (such as a QR code, barcode, or RFID/NFC tag) affixed to the product, its packaging, or its documentation, in accordance with the applicable delegated act. Regarding the structure of these identifiers, the European standard EN 18219 applies; we discuss this further in From QR Codes to Unique URLs.

4. Registering the DPP and ensuring its availability

The passport must be registered in the EU registry and remain accessible for the required duration—even if the company ceases operations. For this reason, the ESPR (Ecodesign for Sustainable Products Regulation) mandates that a backup copy be held by an independent DPP service provider.

5. Managing Access

Not all information is public. The DPP distinguishes between different access levels—for consumers, supply chain operators, repairers and recyclers, supervisory authorities, and customs—thereby protecting sensitive commercial data.

6. Updating Sales Channels and E-commerce

Retailers and marketplaces must ensure that product pages, data feeds, and catalogs display a link or QR code to the passport, accessible prior to purchase.

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Frequently Asked Questions

I am a small retailer; do I have to create the DPP myself? No. However, you must verify that the products you sell include one and ensure it is accessible to customers, including online.

I import from a Chinese supplier who is unfamiliar with the ESPR. What are the risks? If the passport is missing, you cannot legally place the product on the EU market, and the goods may be held by customs. It is advisable to include a requirement to provide DPP data within your supply contracts.

Is the DPP already mandatory for all products? No. The framework becomes active on July 20, 2026, but the obligations apply only to product categories covered by a delegated act or an existing sector-specific regulation. The first such category—certain types of batteries—will be subject to these requirements starting February 18, 2027.

I sell products manufactured by third parties under my own brand. Who is considered the manufacturer? For the purposes of the ESPR, you are: any party that markets a product under their own name or brand assumes the obligations of the manufacturer, including those related to the DPP.

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In Summary

The Digital Product Passport is not a directive requiring national transposition, but an obligation established by a regulation that is directly applicable in all EU Member States. It is being introduced in stages, category by category. The fundamental rule is clear: the party that places the product on the market creates the passport, while the party that sells it makes it accessible.

Acting well in advance is advantageous. Gathering data from suppliers, selecting data carriers and identifiers, and integrating the DPP (Digital Product Passport) into company systems takes months. Companies that arrive prepared turn a compliance requirement into an advantage: greater transparency for customers, better-monitored supply chains, and data ready for markets that reward sustainability.