The manufacturer is responsible for making sure a product has its Digital Product Passport (DPP) when it goes on sale in the EU, wherever the factory is. For goods made outside the EU, the importer that brings them in carries the same responsibility.
Being responsible does not mean building the passport alone. Much of the data sits with suppliers: what a fabric is made of, or which substances of concern are in a coating. The Ecodesign Regulation also leaves open who actually builds and updates each passport. The rules for each product group will settle that, one group at a time. The new toy and detergent laws are more direct: there, the manufacturer creates the passport itself.
Who else has a part to play?
- Importer: makes sure a product made outside the EU has its passport before it is sold in the EU.
- Distributor: checks the passport is there before selling the product on.
- Dealer, including an online shop: makes sure customers can reach the passport, including when buying online.
- Supplier: has no passport duty under the Ecodesign Regulation itself, but in practice supplies the data the manufacturer asks for.
Does this apply yet?
Not under the Ecodesign Regulation. As of October 2026, no product group has its passport rules. Batteries have a separate law, and their passport starts on 18 February 2027.
Where this comes from: Ecodesign Regulation (EU) 2024/1781, Articles 9, 27 to 31; Detergents Regulation (EU) 2026/405, Article 21; Toy Safety Regulation (EU) 2025/2509, Article 19; Battery Regulation (EU) 2023/1542, Article 77.