Obligation
Who needs a Digital Product Passport?
The obligation sits with the economic operator that places the product on the EU market. Which party that is depends on where the product is made and how it reaches the EU — and getting it wrong is costly.
The importer trap: for goods manufactured outside the EU with no EU manufacturer or authorised representative, the passport duty lands on the EU importer — usually the party with the least visibility into the upstream data the passport needs.
The responsible party, by role
- Manufacturer — when established in the EU, creates, registers and signs the passport, and is accountable for the accuracy of its data for as long as the passport exists.
- Authorised representative — when a non-EU manufacturer appoints one, it assumes the full economic-operator obligation, including signing every passport.
- Importer — for goods made outside the EU with no EU manufacturer or authorised representative, the importer becomes the responsible economic operator.
- Distributor / retailer — must verify that a compliant passport exists before making a product available.
The obligation cannot be delegated
If a platform provider registers the passport on your behalf, you — the economic operator — remain legally accountable for the data. A service provider can hold the qualified seal and file on your behalf (a valid model under eIDAS), but responsibility does not transfer.
Why importers are the most exposed
The product data has to come from the supplier — they know the materials, the footprint, the certificates. Building DPP data requirements into procurement contracts is not optional. Importers face maximum exposure with the least upstream data and the least lead time, which is exactly why PassPer built Importer Shield and a no-account supplier-collection portal.
Frequently asked questions
Who is responsible for the Digital Product Passport?
The economic operator that places the product on the EU market — the EU manufacturer, an appointed authorised representative, or, for non-EU goods, the importer.
Does the importer or the manufacturer create the DPP?
For goods made outside the EU without an EU manufacturer or authorised representative, the importer carries the obligation, even though the data must come from the supplier.
Can I outsource the DPP obligation to a platform?
You can have a platform build and file passports and even hold the qualified seal, but the legal accountability for the data remains with you as the economic operator.
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