No, with one exception. Under the EU’s Ecodesign Regulation, a manufacturer outside the EU does not have to appoint an authorised representative for its Digital Product Passport (DPP). If it appoints one anyway, the representative cannot take over the passport duty, which stays with the manufacturer. The product does still need a business based in the EU, usually the importer. Construction products are the exception: there, a single authorised representative is required.
Why can’t a representative take over the passport?
Because the regulation rules it out. A manufacturer may appoint an authorised representative by written mandate. The mandate cannot cover the manufacturer’s core duties: design and manufacture, product information including the passport, and the technical documentation. The passport stays the manufacturer’s responsibility.
So who has to be in the EU?
Someone responsible for the product’s compliance. The EU’s market surveillance rules require products under ecodesign law to have a business established in the EU, and that can be:
| EU-based business | When |
|---|---|
| Importer | The manufacturer is outside the EU |
| Authorised representative | It holds a written mandate for these tasks |
| Fulfilment service provider | No other responsible business is in the EU, for the products it handles |
That business checks the declaration of conformity and technical documentation exist and keeps them available to the authorities, answers their requests, reports risks and helps with corrective action. Each product group’s rules can require its name, contact details and identifier in the passport.
What does the importer have to do?
Make sure the passport and its back-up copy are in place before the product is placed on the EU market. That duty is covered in full in an EU importer’s duties.
Which products are different?
- Construction products: the Construction Products Regulation requires a manufacturer outside the EU to appoint a single authorised representative; see construction products.
- Batteries: the battery passport sits with whoever places the battery on the EU market, and batteries also need an EU-based responsible business.
Can a company outside the EU use the registry?
Yes, once registration opens. It proves its identity with a qualified electronic seal or an electronic attestation of attributes. The EU registry was not yet taking passport registrations in October 2026, and no product group under the Ecodesign Regulation had a passport duty.
Where this comes from: Ecodesign Regulation (EU) 2024/1781, Articles 27 to 29 and 79(3) and Annex III; Regulation (EU) 2019/1020, Article 4; Construction Products Regulation (EU) 2024/3110, Article 23; Battery Regulation (EU) 2023/1542, Articles 77 and 91; Implementing Regulation (EU) 2026/1778, Article 4.