Who is primarily responsible for creating the DPP?

The system operates on a clearly defined allocation of responsibilities across the value chain:

The Manufacturer (EU-Based): If you make it here, you are the lead author. You compile the data, build the passport, and register it in the official EU registry before the product is ever sold

The Importer (Non-EU Products): If the product is made in the US or Asia, the importer acts as the legal bridge. They are responsible for ensuring that a compliant passport exists and is accurate before the goods pass through customs

The Supply Chain (Upstream): These actors are the “data feeders.” While a raw material supplier doesn’t launch the passport, they are legally required to provide the manufacturer with the data they need like chemical content or carbon footprints to build that passport accurately.