Does an importer need to create a DPP?

An importer can be the responsible economic operator, but the answer depends on the product group, applicable legislation and who is placing the product on the EU market.

Imported products are not outside the DPP system

Current Commission guidance says DPP obligations apply to economic operators placing in-scope products on the EU market whether the goods are manufactured inside the EU or imported.

What an importer should establish

• Is this product in scope of a current DPP requirement?
• Which entity is the economic operator placing it on the EU market?
• Who creates/hosts the DPP and who controls the required product data?
• Who registers the DPP and identifiers in the EU Registry?
• What evidence must be obtained from the non-EU manufacturer or suppliers?

Why this becomes a data problem

An EU importer may not own the upstream technical data needed for the passport. Supplier evidence, document revision and the update process therefore need to be contractually and operationally clear before implementation.

Official source: European Commission - DPP for Economic Operators. Checked 28 September 2026.