Find Your ESPR Obligations by Role
The same rules apply differently depending on where you sit in the value chain. This is an orientation guide, not a compliance checklist. Across every role, the economic operator placing the product on the EU market holds legal responsibility for the passport, even when a service provider performs the registration and lifecycle updates.
Raw-material & Component Supplier
You sit upstream of the DPP, but your data is what fills it. Customers in regulated categories will increasingly request embodied carbon, recycled content, and substances-of-concern data well before their own compliance deadlines.
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For iron, steel, and aluminium (both intermediate products in the Working Plan): begin preparing verified material and carbon data. These are among the first categories expected to reach compliance.
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No registration obligation falls directly on suppliers. However, contractual data obligations will increasingly be pushed upstream by customers as their own deadlines approach.
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Manufacturer
If you place the finished product on the EU market, you are the responsible economic operator: you register the passport and are accountable for its accuracy.
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Decide who performs registration (in-house versus a service provider) and confirm your organization can issue compliant unique identifiers and GS1 Digital Link data carriers.
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Map which of your products fall within a priority category and track that category's delegated act; that is what determines your real compliance deadline.
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Brand / Own-Label
If you sell under your own name or mark, you are treated as the manufacturer and carry the passport obligation even if you do not manufacture the product.
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The Article 25 destruction ban applies to large enterprises from 19 July 2026 for unsold apparel and footwear. Five-year records must be maintained to use any derogation.
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Establish supplier data agreements now. Your passport is only as strong as the data your manufacturers and suppliers provide.
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Importer
If you bring a product into the EU from a non-EU manufacturer, the passport responsibility shifts to you. Confirm a valid passport and registry entry exist before goods reach the EU border.
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Customs authorities can check the registry at the border. A missing or invalid passport creates a market-access problem, not only a paperwork issue.
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Verify that your non-EU suppliers can provide compliant data and identifiers. EU requirements cannot be assumed to be tracked by suppliers operating outside the EU.
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Distributor / Retailer
Distributors carry lighter obligations, but not absent ones. You must not place products that lack a required passport on the market, and you should be able to direct customers to it.
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Confirm that products you stock carry a valid data carrier and passport once their category rules apply.
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The Article 25 destruction ban and disclosure rules apply to unsold consumer goods in textiles and footwear.
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