Economic Operators and Their Responsibilities

The answer to "who is responsible for the Digital Product Passport?" is not a single party. ESPR distributes responsibility across roles called "economic operators." For a manufacturer exporting into the EU, understanding these roles means foreseeing who will demand what.

Roles and responsibilities

Manufacturer

The party that designs and produces the product. The core responsibility sits here: create the passport, fill it with accurate data and keep it current. As a manufacturer outside the EU, this obligation concerns you directly once your product enters the EU market.

Importer

The party that brings the product into the EU market. The importer is obliged to place only compliant products (those with a passport) on the market. That is why your EU buyer will demand a passport from you — if they don't, they become liable themselves.

Authorised Representative

The party a non-EU manufacturer gives written authority to take on its obligations within the EU. It is an important mechanism for exporters.

Distributor

Other parties that make the product available in the supply chain. They must not offer non-compliant products and must check for the presence of a passport where required.

Why does responsibility spread along the chain?

Because single-point control does not work. When each link checks the compliance of the one above it, a non-compliant product finds it harder to enter the market. This also explains why the cost of non-compliance rises for everyone.

The practical upshot for exporters

You are in the manufacturer (or authorised representative) role and are the source of the passport. Your EU importer will demand compliance; meeting that demand is the continuation of your business relationship. For early preparation, see our EU exporter compliance checklist and SME preparation guide.

Frequently asked questions