Non-EU factory, EU market: the passport obligations are yours.

EU product law has one consistent principle: someone inside the EU must answer for every product placed on its market. When goods are manufactured outside the EU, that someone is the importer. The Ecodesign for Sustainable Products Regulation (ESPR, Regulation (EU) 2024/1781) and the Batteries Regulation (Regulation (EU) 2023/1542) both follow this logic — so for imported goods, the Digital Product Passport and battery passport duties attach to you, the EU importer, at manufacturer level. This page explains what that means and how a mid-sized importer gets compliant without a compliance department.

In one line: for goods made outside the EU, the importer is the economic operator placing them on the market — which makes the DPP and battery passport a manufacturer-level legal duty of the importer, with distributors only obliged to verify what the importer must guarantee.

Why the duty lands on the importer

Both the ESPR and the Batteries Regulation place their obligations on the economic operator placing the product on the EU market. A manufacturer in Shenzhen, Hanoi or Istanbul has no EU legal presence for market-surveillance authorities to hold to account — so the law transfers the responsibility to the first operator inside the EU: the importer. This is the same architecture EU product law has used for years (CE marking works the same way; the DPP is a data record that complements it, not a replacement). The practical consequence: whatever passport data your factory does or does not prepare, the party a customs officer or market-surveillance authority will address is you.

What "manufacturer-level obligations" means in practice

As the importer you must ensure, before placing the product on the market, that:

a compliant passport exists for each product that an applicable delegated act (or the Batteries Regulation) covers;
its data is accurate, complete and kept up to date — errors are attributed to you, not to the factory that supplied the numbers;
the product carries the required data carrier (in practice a GS1 Digital Link QR or Data Matrix) linking to the passport;
the passport is registered where required — the EU DPP registry opens for registration on 19 July 2026;
it remains accessible for the product's regulated lifetime, in some cases up to 15 years.

And note the scope trap that catches most importers: the Batteries Regulation explicitly applies to batteries incorporated into products. Import an e-bike, an electric forklift or a machine with an industrial battery above 2 kWh, and from 18 February 2027 the battery inside needs its own passport — your responsibility, because you placed it on the market.

Importer versus distributor: who checks, who guarantees

EU product law splits the supply chain into roles with graduated duties, and the difference matters commercially.

Importers guarantee. You carry manufacturer-level duties: the passport must exist, be correct, be registered and stay current. You are also expected to verify your manufacturer's compliance before the goods ship — after arrival is too late if customs detains the container.
Distributors verify. A distributor making the product available must act with due care: check that the passport exists and the data carrier is present and working before selling on. They do not create or maintain the passport.

The line is drawn by the transaction, not the job title: a retailer or wholesaler that buys directly from a non-EU manufacturer is, in law, an importer — with the full obligation set. Many "distributors" discover this only when a shipment is questioned.

A practical path for a 50–500 SKU importer

You do not need a compliance department; you need a repeatable process.

Scope your catalogue. Flag every SKU with an in-scope battery (EV, LMT, industrial above 2 kWh — including inside products) for the fixed 18 February 2027 deadline, and map the rest against the ESPR working plan: textiles, furniture including mattresses, and tyres are the priority final products, with iron and steel and aluminium as intermediates.
Collect supplier evidence now. Spec sheets, test reports, material declarations and certificates your factories already hold cover much of the required data — getting them contractually owed to you per shipment is the real work.
Turn documents into passports. This is the gap PassPer closes: AI extraction reads the supplier documents you already have, a human reviews the result, and the platform issues an eIDAS-sealed, registered passport with a GS1 Digital Link QR — from €79 per month, with a free 30-day pilot and per-shipment verdicts via the Importer Shield.
Work backwards from shipping dates. Goods that ship in late 2026 arrive under 2027 rules; battery-powered stock ordered now must be passport-ready on arrival.

Frequently asked questions

Our supplier says they will "handle the DPP". Are we covered?

Only partly. Your supplier can prepare the data and even create the passport, but under EU product law the economic operator placing the product on the EU market carries the responsibility that a compliant passport exists and is accurate — for non-EU-made goods, that is the importer. You can delegate the work in writing; you cannot delegate the accountability.

We are a distributor buying from an EU-based importer. Do we have the same duties?

No. Distributors have a lighter verification duty: before making a product available, check that a passport exists and is accessible — in practice, that the QR carrier is present and resolves. The heavier duty of ensuring the passport exists, is correct and stays current sits with the importer upstream. If you buy directly from a non-EU manufacturer, however, you are the importer.

We import machines and e-bikes, not batteries. Why does the battery passport concern us?

Because Regulation (EU) 2023/1542 applies to batteries incorporated into or added to products. When you import a finished product with an in-scope battery inside — an LMT battery in an e-bike, an industrial battery above 2 kWh in a machine — you are placing that battery on the EU market, and from 18 February 2027 it must carry a compliant battery passport.

When do DPP obligations actually start for our product categories?

It depends on the category. The battery passport is fixed: 18 February 2027. ESPR passports phase in per product group via delegated acts — the first (iron and steel) is expected around 2026, textiles indicatively 2027, with company obligations biting roughly 18 months after each act enters into force. There is no single go-live date, which is why a per-SKU scope check comes first.

See where you stand — three ways, all free.

Take the 2-minute readiness check, watch the 10-minute interactive walkthrough, or download the full 2026 compliance guide. No account needed.

Free readiness check → See it in action Get the guide (PDF)