Why We Added the Importer to the Passport — and Who Verifies a Non-EU Manufacturer
A Digital Product Passport names the manufacturer. But when the manufacturer sits outside the EU, the party legally responsible for the product on the EU market is the importer — or an EU authorised representative. So the passport needs both. Here's why we added the importer, and how it connects to proving who is actually accountable.
The gap
The manufacturer authors the technical data — materials, carbon footprint, recycled content, substances, packaging. That's true whether they're in Munich or Taipei. But EU product law places the market obligation on the economic operator who places the product on the EU market. For a non-EU manufacturer, that's the importer (or an EU authorised representative). A passport that names only the manufacturer can't show who is accountable inside the EU.
What we added
The passport now carries the manufacturer and the importer — with the importer required when the manufacturer is outside the EU — plus:
- the manufacturing facility identifier (free text, or a GS1 GLN that gets check-digit validated);
- the economic-operator identifier (EORI / EU-OP) of the responsible operator.
These feed the four mandatory identifiers of the EU DPP Registry (Reg (EU) 2026/1778). Basis: ESPR 2024/1781 Art. 7(2)(a); Battery Regulation 2023/1542 Art. 38.
Who does what
| Part | Who |
|---|---|
| The data (composition, footprint, substances…) | Manufacturer — they have it |
| EU market responsibility + identity in the Registry | Importer / authorised representative |
The importer doesn't invent the data — the manufacturer supplies it (via import files or API); the importer reviews it, takes responsibility for what they place on the market, and publishes the passport. So "the manufacturer handles the DPP" is true for the content; the accountability is the importer's.
Our contribution: a verifiable operator identity (eIDAS QSeal)
The responsible EU operator can now cryptographically prove their identity with a qualified electronic seal (QSeal), validated against the EU trusted lists — the verified economic operator of Reg (EU) 2026/1778. A non-EU manufacturer can't hold an EU QSeal, so the importer or authorised representative carries the verified identity. We validate independently (we don't issue seals). One passport ends up carrying the manufacturer's data, the importer's EU responsibility, and an identity anyone can check.
What it looks like for a non-EU brand
A Taiwanese manufacturer prepares the product data and hands it to their EU importer. The importer is the account holder: they take the data in, complete the manufacturer/importer details, verify their company with a QSeal, and publish the passport — registered in the EU with their operator identifier. The manufacturer is named on the passport; the accountable, verified party is the EU operator.
Manufacturer's data, importer's responsibility — one passport
Capture manufacturer and importer, feed the EU DPP Registry, and verify the responsible operator's identity.
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