Who must comply with Digital Product Passport regulation?

The ESPR frames the DPP requirement as part of the regulatory burden on manufacturers, importers and distributors for products placed on the EU market.

The framework is horizontal but actual obligations will be introduced via delegated acts per product group.

Which sectors are in scope first?

Textiles, electronics and batteries are priority sectors according to current analysis, with obligations expected to come into force around 2027.

For each product group the chain of responsibility includes:

• The manufacturer or importer who must make the DPP available.

• The authorised representative or distributor who must ensure the data carrier is accessible to the market.

• Market surveillance authorities who may check the passport as part of compliance obligations.
  
  

In short, if you place a product in the EU and it falls into a group covered by a delegated act, you must provide a compliant DPP as a condition of market access.

Waiting is risky.