Who is responsible for the Digital Product Passport?
The relevant product legislation determines the exact obligation, but current Commission guidance places primary responsibility on the economic operator placing the product on the EU market.
What that responsibility can include
- Compiling the product data required by the applicable legislation.
- Creating the DPP and ensuring the required data carrier is associated with the product/packaging/documentation as specified.
- Registering the DPP in the EU DPP Registry in line with the applicable rules.
- Keeping the information accurate through the product lifecycle where required.
Which economic operator?
Depending on the product group and the applicable legislation, the relevant economic operator may be a manufacturer, importer, authorised representative, distributor, dealer or another listed role. Do not assign responsibility from the company job title alone - confirm the legal role for the product and transaction.
Battery-specific point
For Battery Passports, Article 77(4) states that the economic operator placing the battery on the market must ensure the passport information is accurate, complete and up to date, and may authorise another operator in writing to act on its behalf.
Official sources: European Commission - Economic operators and Batteries Regulation. Checked 28 September 2026.