Importers and the Digital Product Passport

Summary

An importer, under Regulation (EU) 2024/1781, is a natural or legal person established in the Union who places a product from a third country on the Union market. Article 29 sets out the importer's duties for products covered by a delegated act adopted under Article 4. The duties apply only to those products, and from the date set by the delegated act for the product group, which cannot be earlier than 18 months after the act enters into force except in duly justified cases.

Before placing a covered product on the market the importer must ensure three things. The manufacturer has carried out the appropriate conformity assessment and drawn up the technical documentation. The product is accompanied by the information required under Article 7 and the delegated act. And a digital product passport is available in accordance with Article 9 and the delegated act, including a back-up copy of the most up-to-date version stored by a DPP service provider in accordance with Article 10(4). The importer must also check that the product bears the required CE marking or the alternative marking set by the delegated act, and that the manufacturer has met its own identification duties.

The importer's own details must be visible. Under Article 29(3) the importer indicates its name, registered trade name or registered trade mark, postal address and electronic means of contact on the public part of the digital product passport where applicable, and on the product or, where that is not possible, on the packaging or in a document accompanying the product. The contact details must be clear, understandable and legible.

Other duties follow the usual product-law pattern. The importer ensures the product is accompanied by digital instructions in a language that can easily be understood, as determined by the Member State concerned. It ensures that storage and transport conditions do not jeopardise conformity, takes corrective action and informs market surveillance authorities if it believes a product is non-conforming, and keeps a copy of the EU declaration of conformity and the technical documentation available for 10 years after the product is placed on the market, unless the delegated act sets a different period.

The importer is also the economic operator placing the product on the market, so Article 10(3) applies to it. On a request from a dealer or an online marketplace, it must provide a digital copy of the data carrier or the unique product identifier, free of charge, promptly and in any event within five working days, so that potential customers can reach the passport when they cannot examine the product physically.

Who is an importer, and what is a covered product

Two questions decide whether Article 29 applies to you.

Importer

Any natural or legal person established in the Union who places a product from a third country on the Union market. A business outside the Union cannot be an importer in this sense, and a distributor that only supplies products already on the market is not an importer.

Product covered by a delegated act

Article 29 applies to products covered by a delegated act adopted pursuant to Article 4. If your product group is not covered by such an act, the importer duties on the passport do not apply to it, whatever product category it belongs to.

Public part of the passport

The part of the digital product passport that is accessible to the public, where the delegated act provides one. The importer's contact details are to appear there where applicable.

Back-up copy

A copy of the most up-to-date version of the passport that is stored by a DPP service provider, as required by Article 10(4). The importer must ensure that it exists before placing the product on the market.

The importer's duties, article by article

A pre-market check for importers

The structure of Article 29(2) suggests a simple order of work. First confirm that a delegated act covers the product. Then check the supplier's conformity assessment and documentation, the information that must accompany the product, and the passport, including its back-up copy. Only then confirm markings and identification. Because the importer is responsible for ensuring these points, supplier contracts should oblige suppliers to deliver the documents and data in time.

Treat the passport's public part as part of your brand and compliance footprint. Your name, trade mark and contact points will appear there where applicable, and the same details must be visible on the product, packaging or accompanying document. Inconsistent or outdated contact data are a straightforward way to fall short of Article 29(3).

Plan retention before you need it. Ten years of availability for the declaration of conformity and the technical documentation is long relative to many supplier relationships, and the passport back-up copy sits with a third-party service provider. Decide in advance who stores what, in which language, and how a market surveillance authority's request would be answered.

What the text leaves open

Article 29 does not settle the following, and we offer no view on them.

• For which product groups, and from which dates, the importer duties will apply, because that is decided by delegated acts.
• Which language the Member State will require for digital instructions, which is determined nationally.
• How the public and restricted parts of a given passport are divided, which depends on the delegated act.

Exemptions

Importer duties apply only to products covered by a delegated act, and the Commission may exempt a product group from the passport in the cases in Article 9(4).

• Article 9(4): the Commission may exempt a product group where technical specifications are not available or where other Union law already provides digital information that achieves the same objectives.

Acts that decide whether Article 29 applies to you

We have not verified the adoption status of any of them.

• Product-specific delegated acts under Article 4. Application not earlier than 18 months after entry into force, except in duly justified cases.

Where to start

This list is a practical suggestion, not wording taken from the Regulation.

1. List the products you import and check which product groups they belong to.
2. Check whether a delegated act covers any of them, and from which date it applies.
3. Review supplier contracts for obligations to deliver conformity documents and passport data.
4. Verify that your name, trade mark, postal address and electronic contact are consistent and current wherever they will appear.
5. Set up a retention rule for the declaration of conformity and technical documentation, for at least 10 years unless the act says otherwise.

Frequently asked questions

Is a Digital Product Passport mandatory for all products?

No. It becomes mandatory only for product groups covered by a delegated act under ESPR Art 4, and not earlier than 18 months after that act enters into force.

Sources

• Regulation (EU) 2024/1781 of the European Parliament and of the Council of 13 June 2024 establishing a framework for the setting of ecodesign requirements for sustainable products, OJ L, 28.6.2024: Articles 2, 9, 10 and 29

Facts last checked against the Official Journal text on 6 November 2026.