You don't write the passport. You do have to check it.

Most DPP coverage speaks to manufacturers and importers, and distributors conclude the topic is not theirs. That is half right. Under the ESPR's economic-operator provisions, distributors and wholesalers do not author passports — but before making a product available on the EU market they are expected to verify that a compliant passport exists and is accessible. The Battery Regulation takes a similar line. Verification is a lighter duty than authorship, but it is a duty, and it needs a process.

In one line: distributors and wholesalers do not create Digital Product Passports, but before making a covered product available they must verify that a compliant passport exists and is accessible — and the moment they own-brand or source from outside the EU, their duties escalate to importer or manufacturer level.

What the ESPR expects of distributors

The ESPR (Regulation (EU) 2024/1781) allocates duties along the supply chain to "economic operators" — manufacturers, importers, distributors. The passport itself is created and maintained by the operator placing the product on the market: the manufacturer, or the importer for non-EU goods. The distributor's role, in the regulation's framing, is a gatekeeping one: before making a product available, verify that the required passport exists and is accessible — in practice, that the product carries its data carrier and that the carrier leads to a live passport.

The Battery Regulation applies a similar economic-operator logic to battery passports from 18 February 2027. The exact wording differs between the regulations and the delegated acts will add detail per product group, so treat this as the shape of the duty rather than its final letter — but the direction is consistent: goods should not move down the chain unchecked.

What to check, and what records to keep

A workable verification routine is short:

Carrier present — the QR code or Data Matrix is on the product, its packaging or the accompanying documentation, and has not been covered or removed.
Carrier resolves — scanning it opens a passport, not an error page.
Passport matches product — identifiers, model and batch correspond to the goods in front of you, not merely to the product family.
Record the check — note what was checked, when, and which supplier delivered the goods.

Traceability is the other half: economic operators are generally expected to be able to tell authorities who supplied them and whom they supplied. Sensible retention of purchase and sales records against product identifiers covers this. And a standing rule for warehouse and repackaging operations: never strip or obscure the data carrier.

When a distributor stops being "just" a distributor

The lighter distributor duty evaporates in three familiar situations:

Own brand — sell goods under your own name or trademark and EU product law generally treats you as the manufacturer, passport authorship included.
Direct non-EU sourcing — buy from a factory outside the EU and you are the importer placing the goods on the market; ensuring a compliant passport exists is now your job.
Substantial modification — rework a product beyond simple handling and you may take on manufacturer-level responsibility for what you changed.

Many wholesalers do all three across different product lines without noticing the change in legal position. An honest per-line classification — distributor here, importer there, manufacturer-equivalent on the private-label range — is the single most clarifying exercise a wholesale business can do before these rules bite.

A practical operating checklist

To turn the duty into routine:

Classify every product line: distributor, importer, or own-brand manufacturer-equivalent.
Add passport clauses to supplier contracts — passports delivered before goods, costs of non-compliance on the supplier.
Build the four-point verification check into goods-in, with spot-checks per shipment rather than per pallet.
Keep supplier and customer records mapped to product identifiers for the retention period your lines require.
Quarantine, do not sell, anything that fails the check.

For the lines where you are the importer or own-brand manufacturer, verification is not enough — you need to author passports, and that is what PassPer does: AI extraction from the documents your suppliers already provide, human review, eIDAS-sealed and registry-filed. Start with the free readiness check to see which of your lines fall on which side of the line.

Frequently asked questions

Do distributors have to create Digital Product Passports?

No — authoring the passport is the job of the manufacturer, or the importer for goods from outside the EU. The distributor duty is verification: before making a product available, confirm that a compliant passport exists and is accessible via its data carrier. You check; you do not author.

What exactly should a distributor check before selling a DPP-covered product?

At working level: that the data carrier (typically a QR code) is present on the product, packaging or accompanying documentation; that it resolves to a passport; and that the passport matches the product in front of you — identifiers, model, batch. Keep a record of the check and of who supplied the goods, so you can answer a market-surveillance query without archaeology.

When does a distributor become an importer or take on manufacturer-level duties?

Two common triggers: sourcing directly from outside the EU — you are then the importer placing the product on the market — and selling under your own brand or private label, which generally attracts manufacturer-level responsibility. Substantially modifying a product can have the same effect. In those cases the passport duty stops being "verify" and becomes "ensure it exists and is accurate".

What if a supplier delivers stock without a compliant passport?

Do not make it available. Escalate to the supplier, document the non-conformity, and hold the stock until a compliant passport is in place — once the relevant rules apply to that product group, a product without one cannot lawfully be sold, and authorities can order withdrawal. Contract clauses that put the cost of such delays on the supplier are worth agreeing now.

See where you stand — three ways, all free.

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