Many importers assume the Digital Product Passport (DPP) is "the manufacturer's problem". EU law sees it differently: whoever places the product on the EU market is responsible for it. If your manufacturer sits in Shenzhen, Ningbo or Istanbul, a substantial share of the manufacturer's obligations — the product passport included — lands on you, the importer. The fine doesn't get mailed to China; it gets mailed to your office. And the first line of enforcement won't be market surveillance — it will be customs, before your goods are even released for free circulation.
The role-swap shock: why the EU treats you as "the manufacturer"
The ESPR (the Ecodesign for Sustainable Products Regulation, (EU) 2024/1781) — like most EU product legislation — assigns obligations by role: manufacturer, authorised representative, importer, distributor. The twist is that these roles don't depend on what your business card says, but on where the manufacturer is established and who places the product on the EU market.
If the manufacturer is based outside the EU and doesn't appoint an EU authorised representative, the practical burden of the manufacturer's compliance obligations falls on the importer. That's nothing new — the CE-marking world has worked this way for decades — but with the DPP the stakes have changed in kind:
- A piece of paper in a binder is no longer enough. The product passport is a live, online data service with a QR-code data carrier on the product — and it's you who has to guarantee that it exists and is correct.
- The data sits with the manufacturer. Material composition, carbon footprint, recycled content, certificates — you have to extract all of this from the factory in Shenzhen, in a verifiable form.
- The liability, however, sits with you. If the manufacturer supplies bad data — or none at all — the EU authorities will come after you. The sanctions — sales bans, recalls, fines — hit the EU economic operator.
And this is no niche issue: the vast majority of manufacturers of batteries, electronics and textiles sold in the EU are based outside the EU. Which means the first wave of DPP obligations will largely hit not factories, but importers.
What you MUST verify as an importer: the three mandatory questions
The ESPR imposes specific, itemised verification duties on importers before a product may be placed on the market. This isn't "acceptance in good faith" — it's active verification, and failing to carry it out is an infringement in its own right. The three key questions:
| Verification point | What it means in practice | What happens if it's missing |
|---|---|---|
| 1. Does a compliant passport exist? | The product has a valid DPP containing all the data required by the delegated act for its category, and it is registered in the EU's central DPP registry. | The product cannot be placed on the market. If you do it anyway, you're committing an infringement — placing a non-compliant product on the market is explicitly prohibited. |
| 2. Does the data carrier work? | The QR code (or NFC tag) is physically present on the product/packaging in the location prescribed by the rules, it scans, and it actually points to that product's passport. | A formal non-conformity — market surveillance can object, and customs can hold up your shipment. |
| 3. Does the data match the customs declaration? | The passport's unique identifier and product data are consistent with what you declare on the customs declaration (commodity code, quantity, product identifiers). | In case of a mismatch, customs can block release for free circulation — your goods sit at the border while storage charges tick away. |
An important nuance: verification doesn't stop at "there's a QR code on the box". You have to be able to demonstrate that the content of the passport meets the category-specific requirements — which means knowing which data fields the relevant delegated act prescribes. If you're still getting to grips with the basics, start with our What is a DPP? article.
The customs link: electronic checks before your goods enter the market
The toughest enforcement element of the DPP system isn't the fine — it's the border. The ESPR ties the product passport into the customs procedure:
- By 19 July 2026, the Commission must set up the EU's central DPP registry (ESPR Article 13) — a central database that stores the unique registration identifiers of product passports and tells you where each passport itself can be accessed.
- At release for free circulation, the customs declaration must include the product passport's unique registration identifier for products already subject to the DPP obligation.
- The customs authority checks electronically whether the declared identifier exists in the registry and matches the declared commodity code. This is no spot check: it's a machine-driven, automatable verification that will evolve over time into a fully automated process integrated with the customs systems.
The formula is brutally simple: no valid passport identifier → no release for free circulation → your goods don't enter the EU market. A container of battery-powered appliances stuck at a terminal in Rotterdam or Koper racks up storage fees by the day — plus the commercial damage if seasonal goods miss their season.
That's why, for an importer, the DPP isn't "compliance paperwork to sort out sometime later" — it's a logistical precondition: the passport has to be ready and registered before the ship docks.
What to put in your supplier contract: sample clauses you can adapt
If the liability is yours but the data is the manufacturer's, then the contract has to build the bridge between the two. Experience shows that Chinese manufacturers do deliver on specific, contractually fixed data obligations — but not on the vague "shall provide all necessary documents" boilerplate. A few clauses worth building in (tailored to your situation with your lawyer):
"The Supplier undertakes to provide all data required for the digital product passport of the Product under Regulation (EU) 2024/1781 (ESPR) and the applicable delegated act — including material composition, recycled content share, carbon footprint calculation and supporting certificates — via the electronic interface designated by the Buyer, in English, within 15 working days of order confirmation."
"The Supplier warrants the accuracy and completeness of the data provided and undertakes to notify the Buyer in writing of any change to that data — in particular any change of material, component or manufacturing site — at least 30 days before the change takes effect."
"Should the Buyer incur regulatory sanctions, customs delays or third-party damage claims as a result of incomplete or inaccurate data, the Supplier shall fully indemnify the Buyer. The Buyer is entitled to withhold 20% of the purchase price until the data has been supplied in full."
The third clause — the payment retention — is the most effective in practice: an indemnity promise is hard to enforce against an overseas manufacturer, but an unpaid 20% motivates immediately. We cover data-collection strategies in more depth in our article on gathering supplier data.
The timeline through an importer's eyes: when do you need what on the table?
Deadlines vary by category — you'll find the full picture in our ESPR deadlines article; here are the milestones that matter to importers:
| Date / period | What happens? | What it means for you as an importer |
|---|---|---|
| 19 July 2026 | Deadline for the Commission to set up the EU's central DPP registry (ESPR Article 13). | The infrastructure for registering passport identifiers becomes available; customs-side electronic checks kick in category by category, as each DPP obligation takes effect — starting with batteries from 2027. |
| 2026 (expected) | Delegated act for iron and steel products — one of the pioneer categories. | If you import steel products (fittings, profiles, fastening hardware), the compliance deadline is expected around 2028 — supplier data collection needs to start now. |
| 18 February 2027 | Battery passport becomes mandatory: LMT batteries, industrial batteries above 2 kWh, EV batteries. | Importing Chinese batteries, cordless tools or e-mobility products? This is the first hard, fixed date — details in our battery passport article. |
| 2027 (expected) | Adoption of the textile delegated act. | You'll have at least 18 months from adoption to comply — putting the live textile DPP obligation between late 2028 and 2029. Our textile industry article has the details. |
| 2028–2030 | Delegated acts for further priority categories (furniture, mattresses, aluminium), plus the compliance deadlines for the first categories (steel, textiles, tyres); electronics can enter the working plan at the earliest after the 2028 mid-term review. | Based on the ESPR working plan, most consumer-goods importers will get their turn. |
The trap lies in the "I've still got time" logic: at least 18 (typically 18–36) months pass between the adoption of a delegated act and mandatory application — but extracting complete, verifiable data from a Chinese supply chain takes six months to a year, especially when your manufacturer has its own tier of raw-material suppliers behind it. Whoever starts when the delegated act is published will be scrambling in the months before the deadline.
Data collection without the email ping-pong: let your manufacturer do the work
The typical scenario goes like this: you send the manufacturer an Excel sheet, it comes back half filled in, three fields are in Chinese, the carbon-footprint cell is empty, and the certificate PDF belongs to a different product. Five rounds of email, two months gone, and still no publishable data. Now multiply that by the number of SKUs in your catalogue.
The scalable solution is to flip the process around:
- You define the framework: the product category's schema specifies exactly which fields are needed — no more, no less.
- The manufacturer fills it in: via a simple web form that requires no login, in their own language environment, with mandatory fields and format validation — so half-finished data can't even get through.
- You approve: you review the incoming data package and merge it into the passport with one click — or send it back for correction with a specific error message.
This puts the burden of supplying data where the data is created — with the manufacturer — while control stays where the liability sits: with you. What's more, the whole process is logged: you can prove to the authorities, even after the fact, when you received which data from whom, and what you approved. For the full preparation journey, our DPP readiness checklist is a good starting point.
How Veridyn helps
Veridyn was built precisely for the situation most importers are in: the liability is here, the data is over there — and the two need to be connected efficiently.
- Supplier portal: you send your Chinese manufacturer a secure link that requires no login, where they upload the schema-defined data and certificates themselves — you review, approve and merge it into the passport with one click. No more Excel ping-pong.
- Category-schema editor, no coding required: batteries, textiles, steel — the schema walks you through which fields are mandatory, so you know exactly what to extract from your supplier.
- Document uploads: certificates and test reports attached to the passport, all in one place — instantly at hand when the authority or customs asks.
- Version history with a hash chain: every data change goes into a tamper-proof log — you can prove when you received what from the manufacturer and what you published.
- QR + GS1 Digital Link and a public passport in 24 EU languages: the data carrier and the multilingual display come ready-made — you don't have to figure them out yourself.
- Layered access: the public, legitimate-interest and authority data scopes are kept separate — your trade secrets (such as your sourcing) never end up in the public view.
If you want to know where you stand, take the free DPP readiness test — in 5 minutes it shows you where you're exposed as an importer. If you'd like to see how all this looks in action, check out the live demo, or jump straight in with the free starter plan — your first passport can be ready before your next container docks.