Is the manufacturer always responsible for a Digital Product Passport?

No. Responsibility depends on who acts as the relevant economic operator for the product on the EU market and on the product-group rules. An importer of a good manufactured outside the EU often carries obligations that a purely domestic manufacturer would carry in another chain.

Does a retailer always need to create a DPP?

No. A retailer that only distributes goods already placed on the market by another operator is not automatically the operator that must create the passport. A retailer that imports, or that sells private-label goods as manufacturer, may be in a different position. This is not a SOURCE classification of your contracts.

Who is responsible for a Digital Product Passport?

Responsibility is not a slogan. It follows the economic operator who places the relevant product on the EU market and the requirements defined for that product group.

Written by SOURCE Research. Published 18 August 2026. Last reviewed 18 August 2026. Not legal advice.

Direct answer

Who is responsible for creating a Digital Product Passport?

Under the ESPR framework, obligations attach to economic operators. Which operator must provide which information is specified in the applicable product-group measure. Manufacturer, authorised representative, importer, distributor and fulfilment-service provider are distinct roles. Private-label arrangements can shift who is treated as manufacturer. SOURCE does not decide your legal role.

Regulation (EU) 2024/1781 (ESPR)

Roles (operational reading)

Role	Typical question	Do not assume
Manufacturer	Did we make the product and place it on the Union market?	That a brand name on the box always equals manufacturer.
Importer	Did we first place a third-country product on the Union market?	That the foreign factory will carry the EU information duty.
Distributor / retailer	Do we only make the product available, or do we also import or own the brand?	That every retailer must create a DPP for every SKU.
Private-label brand owner	Are we presenting ourselves as manufacturer?	That the contract manufacturer is automatically the responsible operator in the EU.

FAQ

Is the manufacturer always responsible for a Digital Product Passport?: No. Responsibility depends on who acts as the relevant economic operator for the product on the EU market and on the product-group rules. An importer of a good manufactured outside the EU often carries obligations that a purely domestic manufacturer would carry in another chain.
Does a retailer always need to create a DPP?: No. A retailer that only distributes goods already placed on the market by another operator is not automatically the operator that must create the passport. A retailer that imports, or that sells private-label goods as manufacturer, may be in a different position. This is not a SOURCE classification of your contracts.