Depending on the product group and applicable legislation, importers can be among the economic operators involved in DPP obligations. The practical challenge is often obtaining reliable upstream information from a manufacturer outside the EU.
The Commission states that the primary responsibility for DPP creation and accuracy rests with the economic operators placing the product on the EU market. The exact actor and obligations depend on the applicable product legislation, so an importer should first establish its role for the specific product.
Critical fields may sit with a manufacturer or component supplier that does not use the same data structure.
A value in an email is not the same as a current declaration or traceable source document.
Someone in the EU organisation still needs to own gaps, updates, registration and lifecycle maintenance.