Shops and other sellers do not create the Digital Product Passport (DPP), but they do have to pass it on. A dealer, any business offering products to end users in a shop or online, must make sure customers can easily reach the passport. A distributor must check the passport is there before selling. Online marketplaces mainly have to cooperate with the authorities. As of October 2026, no product group under the Ecodesign Regulation needs a passport yet.
Who has to do what?
| Seller | What the Ecodesign Regulation asks |
|---|---|
| Distributor | Check, before selling, that the product is labelled or linked to its passport |
| Dealer, in a shop or online | Make sure customers and would-be customers can easily reach the passport |
| Anyone selling at a distance | Show the manufacturer’s name and contact, a picture of the product and, for a manufacturer outside the EU, the business responsible for it in the EU |
| Online marketplace | Work with market surveillance authorities, act on their orders about non-compliant listings, and keep a single contact point |
Does a marketplace have to show the passport on the product page?
Not under the text of the regulation, which puts that duty on dealers. The Commission’s FAQ expects more: “Online marketplaces will be required to make the DPP easily accessible on the product page.” That is guidance for now. A marketplace that also sells products in its own right appears to count as a dealer under the definitions, and then the dealer duty applies.
Where does a seller get the QR code from?
From the business that placed the product on the EU market. Dealers and online marketplaces can ask it for a digital copy of the carrier or identifier, or a web link. It must provide this free of charge within five working days. The toy and construction products laws have the same rule. How the passport is then shown to shoppers is covered in seeing a passport before purchase.
When does a seller become the manufacturer?
When it sells a product under its own name or brand, or changes a product already on the market in a way that affects whether it complies. It then takes on the manufacturer’s passport duty in full.
Where this comes from: Ecodesign Regulation (EU) 2024/1781, Articles 2(54) and (55), 10(3), 30, 31, 34, 35 and 36; Toy Safety Regulation (EU) 2025/2509, Article 19; Construction Products Regulation (EU) 2024/3110, Article 77; Commission DPP FAQ.