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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