The system operates on a clearly defined allocation of responsibilities across the value chain:
The manufacturer: wherever it is based, the manufacturer must make sure a passport and its back-up copy are available when it places a covered product on the EU market. The economic operator placing the product on the market uploads its identifiers to the EU registry. The registry went live on 20 July 2026, but its user guide of 16 September 2026 says passports cannot be registered yet.
The importer: for a product made outside the EU, the importer is the EU-established business that places it on the market. Before doing so, it must check that the passport and its back-up copy exist.
Upstream suppliers: the ESPR puts the passport duties on the economic operators that place the product on the EU market, such as the manufacturer and the importer. In practice those operators ask suppliers for the data they need, such as material content. Where a supplier has no operator or facility identifier, ESPR Article 12 has the operator creating the passport request one on its behalf.