compliance

Importing Products into the EU: DPP Responsibilities

What non-EU supply chains must prepare for the Digital Product Passport, importer obligations, data gaps, and practical readiness steps.

3/27/2026 · 8 min read · InfoDPP

Editorial update, 22 July 2026: the Commission describes the production DPP Registry as operational, with registration available through a secure interface or API and a separate testing environment. Importers can use the economic-operator workflow, while product-specific registration still depends on the applicable semantic catalogue and sector rules. The launch does not activate universal border checks: the Registry-to-customs interconnection is due by 6 August 2030.

Status, 20 September 2026: Parliament approved the customs reform at second reading and the final act was signed on 16 September. OEIL lists procedure 2023/0156(COD) as completed, awaiting publication in the Official Journal. This does not bring forward DPP obligations or the Registry-to-customs interconnection deadline of 6 August 2030. European Parliament procedure.

Why Importers Face a Different Kind of DPP Pressure

The Digital Product Passport framework does not only affect EU-based manufacturers. Importers and authorised representatives have defined duties under the applicable product law when products are placed on the EU market, both under the ESPR umbrella and under standalone frameworks for batteries, construction products, toys and detergents. The exact allocation is sector-specific, so these roles should not be treated as interchangeable.

In practice, this means that if you import a product into the EU and the relevant act requires a Digital Product Passport, you must ensure the passport exists, the data is accurate, and the data carrier is accessible. Manufacturing the product outside the EU does not reduce the obligation; it makes implementation more difficult.

Battery passports and customs declarations

For products covered by ESPR, Article 15 provides for the unique registration identifier to be supplied when the product is declared for release for free circulation. The product obligation and the technical customs connection must both be checked before treating this as an operational procedure.

Battery passports follow a different rule. The September 2026 FAQ for batteries, question 4.1, explains that the passport must be registered in the EU DPP Registry, but its registration identifier does not have to be entered in the electronic customs declaration. This exception concerns the regime under Regulation (EU) 2023/1542. It does not remove the battery passport, registration or other import obligations.

An importer should therefore identify the applicable product law before adding a DPP identifier to its customs process. The battery clarification is not evidence that the same exception applies to toys, detergents or future ESPR product groups.

Who is responsible for an imported battery

The September FAQ addresses finished batteries, including batteries installed in imported machines or vehicles. In that situation, the importer normally becomes responsible for the battery passport. If cells or unfinished modules are imported for assembly in the EU, responsibility instead falls on the operator that completes the safely functioning battery and places it on the market or puts it into service. These are battery rules, not a general allocation of responsibility for every DPP.

A written mandate can let a supplier or another operator, including one outside the EU, create or update battery passport data. It does not transfer the responsible operator’s legal obligations or automatically make the authorised operator an EU manufacturer or importer. The practical cases are explained in our guide to finished batteries.

What Is Already Confirmed

Several elements of the importer’s position are legally clear today:

ESPR Regulation (EU) 2024/1781, Article 29, sets importer obligations for products covered by applicable delegated acts. The corresponding sector provisions must be checked separately; the duties are not identical across every passport regime.
importers must verify that a product bears a valid unique product identifier and data carrier before placing it on the market
importers must ensure that the manufacturer has drawn up the required technical documentation and that the DPP is accessible
where importers consider a product to be non-compliant, they must not place it on the market until it has been brought into conformity
where the applicable product law requires it, importers must keep the declaration of conformity or equivalent evidence and ensure technical documentation is available for market-surveillance authorities

What is not yet fully fixed:

the data fields for future ESPR product groups and any later sector refinements; batteries, toys, detergents and the CPR already define substantial baseline datasets in their own laws
how the six cited horizontal standards, the Registry data models and sector-specific rules will apply to each product category; two standards and many product-specific implementation details remain pending
how customs authorities will practically verify DPP compliance at the border (see DPP as Customs Tool)

Where the Data Gap Hits Hardest

EU manufacturers may already hold much of the required data in ERP, PLM and quality-management systems. Importers relying on non-EU suppliers often need to obtain that information from other organisations:

1. Material composition and substance declarations

Non-EU suppliers may not routinely provide structured composition data in a format compatible with EU DPP requirements. Data arrives as PDF certificates, internal test reports, or not at all.

2. Carbon and environmental footprint evidence

Where the applicable product rules require environmental performance data, follow the prescribed calculation and verification methods. Those rules determine when primary data is required and whether secondary datasets are acceptable. Check what your suppliers can provide before identifying any remaining gaps.

3. Manufacturing facility and process information

Some product rules require information about production sites or manufacturing processes; this is not a universal DPP field list. Where relevant, check whether supplier records identify the factory and process associated with each product or batch.

4. Unique product identification

The product identifier must be assigned before the product enters the EU market. Importers need a clear process for ensuring that their suppliers apply identifiers consistently and that those identifiers connect to the DPP registry.

Five Practical Steps for 2026

Even before sector-specific delegated acts define every data field, importers can close the most critical gaps now.

1. Find out which data your suppliers can provide

Ask your key suppliers which data they can provide in a structured format. Check whether they have product composition information, test certificates, factory identification and environmental declarations. Record what is missing and who needs to supply it. Use that list to decide what to work on first.

2. Standardise your data request templates

Instead of collecting different data from different suppliers in different formats, create one repeatable data request that covers the fields most likely to appear in future DPP delegated acts: identifier, composition, origin, environmental evidence, and supporting documents.

3. Clarify your role in the economic operator chain

Determine your legal role before allocating tasks. Under ESPR Article 34, an importer placing a covered product on the market under its own name or trademark is treated as the manufacturer and must meet the manufacturer’s obligations.

4. Test a product record end-to-end

Pick one product line from one supplier and attempt to build a complete structured record: product identity, composition, environmental data, supplier evidence, and a simulated data carrier. This exercise helps identify gaps and time-consuming steps.

5. Monitor delegated acts and standalone regulations relevant to your product categories

Confirmed standalone regulations already carry fixed DPP application dates, batteries (18 February 2027), detergents (23 September 2029) and toys (1 August 2030). The ESPR Working Plan 2025 to 2030 identifies the indicative first wave of priority product groups under ESPR delegated acts, textiles, iron and steel, furniture, tyres and electronics, whose exact DPP application dates will follow once the delegated acts are adopted.

What Customs Enforcement Means for Importers

The European Commission, in its March 2026 answer to a parliamentary question, confirmed that DPP data will be integrated into EU customs enforcement systems, including the Single Window environment. Regulation 2026/1778 now makes the Registry side concrete, while ESPR Article 15 sets 6 August 2030 as the deadline for the technical interconnection. These measures establish the planned connection; they do not mean that every border already performs a complete DPP check.

Once the relevant DPP and customs rules apply, products that require a passport may face delays at the border, additional checks or refusal of release if their passport data is missing or invalid. For details, see DPP as Customs Tool: What the Commission Confirmed.

Common Mistakes Importers Make

1. Assuming the manufacturer handles everything

Under ESPR, the importer has independent verification obligations. Where the regulation requires verification, the manufacturer’s assurance alone does not replace the importer’s checks.

2. Treating DPP as a labelling project

The data carrier (QR code, RFID) is the visible layer. The actual work is building the structured data record behind it. Designing the label before organising the required data can leave gaps that become apparent during a market-surveillance check.

3. Waiting for the final delegated act before collecting any data

By the time the specific data fields are published, the implementation timeline is typically tight. Organising supplier data early can reduce the work needed once the final requirements are known.

Official Sources

Want to organise product data and supplier documents? Try OriginPass.eu and start preparing your digital product passport.

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