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 supply its data, and customers in regulated categories will increasingly request embodied carbon, recycled content, and substances-of-concern data well before their own deadlines.

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For iron, steel, and aluminum (both Working Plan intermediate products), prepare verified material and carbon data now, since they are among the first categories expected to reach compliance.

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No registration obligation falls directly on suppliers, but customers will increasingly push contractual data obligations upstream as their deadlines approach.

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Manufacturer

If you place the finished product on the EU market, you are the responsible economic operator, registering the passport and accountable for its accuracy.

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Decide who registers (in-house or a service provider) and confirm you can issue unique identifiers and data carriers that comply with ISO/IEC 15459 (GS1 Digital Link is one option).

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Map which products fall in a priority category and track its delegated act, which sets your real compliance deadline.

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Since 15 July 2026, conformity with the six cited DPP standards (EN 18216 and EN 18219 to 18223:2026) is presumed to satisfy ESPR Articles 10 and 11. Name them as your build specification and require conformance from your DPP platform or service provider in contracts and RFPs.

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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 without manufacturing the product.

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The Article 25 destruction ban applies to large enterprises for unsold apparel and footwear from 19 July 2026, and any derogation requires five-year records.

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Set up supplier data agreements now, since your passport is only as strong as your manufacturer and supplier data.

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Specify the six cited DPP standards (EN 18216 and EN 18219 to 18223:2026) in DPP platform selection and supplier data agreements, and make conformance a contract requirement, because since 15 July 2026 conformity carries a presumption of conformity with ESPR Articles 10 and 11.

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Importer

Before placing goods from a non-EU manufacturer on the EU market, you must make sure a valid passport exists, upload its registry data, and add your contact details to it (ESPR Arts. 13(4) and 29), all before the goods reach the EU border.

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Customs authorities can check the registry at the border, so a missing or invalid passport is a market-access problem, not only paperwork.

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Verify that non-EU suppliers can provide compliant data and identifiers, since they cannot be assumed to track EU requirements.

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Ask non-EU suppliers whether their passport data conforms to the six cited DPP standards (EN 18216 and EN 18219 to 18223:2026), which since 15 July 2026 carries a presumption of conformity with ESPR Articles 10 and 11. You must make sure a valid passport exists before placing their goods on the market.

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Distributor / Retailer

Distributors carry lighter obligations but must check, before making a product available, that it is linked to its required passport (ESPR Art. 30), and should be able to direct customers to it.

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Confirm that stocked products 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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Frequently Asked Questions

Who is legally responsible for a Digital Product Passport?
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.
Do importers have DPP obligations?
Yes. Before you place a product from a non-EU manufacturer on the EU market, you must make sure a valid passport exists, upload its registry data, and add your contact details to the passport (ESPR Arts. 13(4) and 29). Confirm this before goods reach the EU border, where customs can check the registry.
Do raw-material suppliers need to register a passport?
No registration obligation falls directly on suppliers, but your embodied-carbon, recycled-content, and substances-of-concern data fills your customers' passports, and contractual data obligations are increasingly pushed upstream as their deadlines approach.