Who is responsible for creating an EU Digital Product Passport?
For an ESPR product covered by a delegated act, start with the that places the product on the EU market or puts it into service. ESPR Article 10 requires the operator placing the product on the market to make available a back-up copy of the DPP through a DPP service provider. Article 13 requires the operator placing the product on the market or putting it into service to upload the required registry data.
For manufacturers, Article 27 adds a direct duty to ensure that a DPP and its current back-up copy are available for covered products. Article 9 then requires the product-group delegated act to specify the actors that create the DPP or update passport data, what they may change, and the arrangements for doing so.
- Manufacturer: ensure the covered product has the required DPP and current back-up copy, and keep the passport data accurate, complete, and up to date.
- Imported product: the importer must check before placing the product on the EU market that a DPP is available in accordance with ESPR Article 9 and the applicable delegated act.
- Distribution: the distributor must verify, before making a covered product available, that it is labelled or linked to a DPP where the delegated act requires it.
- Authorised representative: a manufacturer may appoint one by written mandate, but Article 28 says the manufacturer's Article 27(1) obligations, including DPP availability, cannot form part of that mandate.
- Updates: do not give write access broadly; follow the delegated act's rules on which actors may introduce or update which data.
Articles 9, 10, 13, 27, and 28 identify creation and update rules, placing-on-market duties, manufacturer DPP availability, and the limit on an authorised representative's mandate.
Supports treating DPP design as a product-group and supply-chain implementation exercise rather than a single universal owner rule.