Six Economic Operators, Not Four: Who Actually Owes a Digital Product Passport
Ask most DPP platforms what an economic operator is and you get four answers: manufacturer, importer, distributor, authorised representative. That is the list in EN 18219 §6, and it is the list in most vendor schemas.
It is not the list in the law.
Regulation (EU) 2024/1781 (ESPR), Article 2, point (46):
'economic operator' means the manufacturer, the authorised representative, the importer, the distributor, the dealer and the fulfilment service provider;
Six. The two that go missing in most implementations — the dealer and the fulfilment service provider — are not edge cases. The dealer is the shop, the website, the marketplace listing: the last party between the product and the customer. The fulfilment service provider is the warehouse that stores, packs and ships on someone else's behalf. Between them they touch most of what actually reaches a European buyer.
The European Commission's own economic operators page names all six. If your DPP system only models four, there are two roles that cannot describe themselves in your data — and both of them carry obligations of their own.
The six roles, and what each one owes
| Role | ESPR definition | DPP obligation |
|---|---|---|
| Manufacturer | Art. 2(42) — makes the product, or has it made, and markets it under their own name or trademark | Art. 27(1)(c) — must ensure a DPP is available, including a back-up copy held by a DPP service provider |
| Authorised representative | Art. 2(43) — established in the Union, acting on a written mandate from the manufacturer | Art. 28 — performs the mandated tasks; Art. 27(1) is explicitly excluded from the mandate |
| Importer | Art. 2(44) — established in the Union, places a third-country product on the Union market | Art. 29(2)(c) — same DPP-and-backup check as the manufacturer, before placing on the market |
| Distributor | Art. 2(45) — in the supply chain, other than manufacturer or importer, makes the product available | Art. 30(2)(a) — must verify the product is linked to a DPP before making it available |
| Dealer | Art. 2(55) — a distributor or anyone who offers or displays products to end users, including distance selling | Art. 31(2) — must ensure the DPP is easily accessible to customers and potential customers |
| Fulfilment service provider | Definition taken from Art. 3(11) of Regulation (EU) 2019/1020 | Art. 33 — warehousing, packaging, addressing and dispatch must not jeopardise compliance |
Four of the six carry a DPP obligation written directly into the regulation. The authorised representative's is inherited from the mandate. Only the fulfilment service provider's obligation is about physical handling rather than data — and even that becomes a data question the moment a data carrier is a label that can be covered by a shipping sticker.
Three things that surprise people
1. The dealer has an obligation of their own
Article 31(2) is short and rarely quoted:
Dealers shall ensure that the digital product passport is easily accessible for customers and potential customers, including in the event of distance selling, as set out in Article 9(2), point (e) […]
This is not the brand's obligation delegated downward. It is the dealer's own. A retailer selling your product online has to make your passport reachable from their listing, and cannot discharge that by pointing at a QR code printed on a box the online customer has never seen.
For a brand, this reframes what the passport is for. It is not only a thing you publish so a regulator can check it. It is a thing your retail channel needs in order to be compliant themselves — which means the ones who resell you have a reason to ask you for it, and a reason to care whether the link actually resolves.
2. You have five working days to hand over the carrier
Article 10(3):
The economic operator placing the product on the market shall:
(a) provide dealers and providers of online marketplaces with a digital copy of the data carrier or the unique product identifier, as relevant, to allow them to make the data carrier or the unique product identifier accessible to potential customers where they cannot physically access the product;
(b) provide the digital copy referred to in point (a) or a webpage link free of charge promptly and in any event within five working days of receiving a request to do so.
A dealer or marketplace can ask, and the clock starts. Free of charge, five working days. In practice this means the QR image and the passport URL have to be exportable per product, in bulk, by someone in your commercial team without a developer — because the request will come from a retail partner, not from an authority, and it will come with a purchase order attached.
Most brands preparing for ESPR have thought about how to publish a passport. Fewer have thought about how to hand ten thousand of them to a retailer's product feed on a week's notice.
3. Private label turns a distributor into a manufacturer
Article 34:
Importers or distributors shall be considered manufacturers for the purposes of this Regulation where they:
(a) place a product covered by a delegated act adopted pursuant to Article 4 on the market under their name or trademark; or
(b) modify such a product already placed on the market in a way that affects compliance […]
This is the clause that catches wholesalers and retail groups with own brands. A distributor who buys a generic product and sells it under their own label is not a distributor for that product — they are the manufacturer, with the full Article 27 obligation set, including creating the passport and arranging its backup.
The practical consequence is that a single company is usually several roles at once, per product line rather than per company. The same builders' merchant might be a distributor for the branded goods it resells, a manufacturer for its own-label range, and an importer for what it brings in directly from outside the Union. A DPP schema with one role field per company cannot express that. The role belongs to the product, not the letterhead.
The backup copy is part of "a DPP is available"
Worth isolating, because it is easy to read past. Both Article 27(1)(c) (manufacturers) and Article 29(2)(c) (importers) do not simply require that a passport exists. They require:
a digital product passport is available […] including a back-up copy of the most up-to-date version of the digital product passport stored by a digital product passport service provider in accordance with Article 10(4)
And Article 11(e) says why:
the digital product passport shall remain available for the period specified in delegated acts […] including after an insolvency, a liquidation or a cessation of activity in the Union of the economic operator responsible for the creation of the digital product passport
A passport that only exists on your own infrastructure is not a compliant passport under Article 27(1)(c), however well-formed it is. The backup host is not a nice-to-have bolted on at the end; it is inside the definition of the obligation. What a backup host is, and how DPP Agent provides one.
The role identifier is not free text
EN 18219 §6.2.2 requires that the economic operator be identified by a scheme registered under ISO/IEC 6523 — an LEI, a GS1 Global Company Prefix, a PEPPOL identifier and so on. A company name typed into a field is not an operator identifier, however correct the spelling.
Combined with Article 2(46), that gives the two halves of a compliant operator block: a role drawn from the six the regulation names, and an identifier drawn from a registered scheme. Get either one wrong and the block is decorative.
When this becomes enforceable
The obligations above apply to products covered by a delegated act adopted under Article 4. No delegated act, no obligation — which is why the sequence of those acts is the only timeline that matters. The Commission's first ESPR working plan sets it out:
| Year | Product group |
|---|---|
| 2026 | Iron and steel |
| 2026–2029 | Energy-related products |
| 2027 | Textiles, tyres, aluminium |
| 2028 | Furniture |
| 2029 | Mattresses, ICT products |
After a delegated act is adopted there is a transition period of at least 18 months before its requirements apply.
Two things follow from how that plan is written. It is indicative, and it gives years rather than dates — so any calendar built on it, ours included, places a category at the start of the year the plan names and treats that as a floor rather than a promise. And the binding date for any category is the one in its own delegated act. Until that act exists, the 18-month transition is the only interval you can actually count on, which makes it the number worth planning against.
Our deadline checker follows the working plan category by category, with the transition rule stated on every row.
What to do with this
- Work out which roles you hold, per product line. Most companies of any size hold two or three. Own-label ranges are the ones to check first, because Article 34 is unforgiving.
- Get an operator identifier under a registered scheme. If you do not have an LEI, that is a short application through an accredited issuer, and it is the identifier most likely to be accepted across the ESPR, battery and packaging regimes at once.
- Make the carrier exportable. Per product, in bulk, retrievable by a non-developer. Article 10(3) gives you five working days from a request you cannot predict.
- Arrange the backup host. It is not a later problem. Article 27(1)(c) puts it inside the definition of having a passport at all.
- Check your schema models six roles. If your platform only offers four, ask what it expects a dealer or a fulfilment provider to select.
DPP Agent's schemas carry all six roles, and the validator checks the operator identifier against the ISO/IEC 6523 requirement rather than accepting a company name. You can test any passport at dppagent.com/validate without an account.
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Sources
Primary sources used in this article:
- Regulation (EU) 2024/1781 (ESPR) — Article 2(42)–(46) and (55), Articles 9, 10, 11, 27, 28, 29, 30, 31, 33, 34 — EUR-Lex full text
- Regulation (EU) 2019/1020 — Article 3(11), definition of fulfilment service provider — EUR-Lex
- European Commission — Digital Product Passport: economic operators — single-market-economy.ec.europa.eu
- ESPR Working Plan 2025–2030 — European Commission Green Forum
- EN 18219 — Unique identifiers, §6.2.2 — available from SIS or en-standard.eu