At what point in the supply chain does the passport apply?

A question that comes up constantly from component makers and B2B suppliers: does this apply to me, or only to whoever sells the finished product?

The legal answer is precise. The practical answer is wider, and the gap between them is where suppliers get caught.

The legal trigger

The digital product passport (DPP) must be active and registered when a product is placed on the EU market, meaning when it is first made available on the EU market.

For EU-manufactured products: before they are first sold or distributed within the EU.

For imported products: before they can be released for free circulation by customs at the EU external border.

Depending on whether the product is made inside or outside the EU, the responsibility to create the passport and register its identifiers falls on the manufacturer, the authorised representative, the importer, the distributor, the dealer or the fulfilment service provider.

The purpose is to provide essential information, public and restricted, to all actors entitled to it across the product's lifecycle, from design and distribution through repair and recycling.

What that means for a component supplier

If you sell a component into another manufacturer who assembles it into a finished product, the passport obligation for that finished product sits with them, not with you.

So the legal answer is often "not you". And it is almost irrelevant.

Your customer cannot complete their passport without data about your component: its composition, its origin, its substances of concern, the facility that made it. They will ask you, and they will ask before their deadline because they cannot leave it to the end.

The requirement therefore reaches you through a contract rather than a regulation, which is the same mechanism described in no data, no sale. Contracts arrive earlier than regulators and they have commercial consequences that are faster and more direct.

Three cases worth checking

Semi-finished goods. Whether a product placed on the market is a finished product for passport purposes depends on the delegated act for that category. Metal stock, fabric and components can be in scope in their own right, particularly in categories like iron and steel that are scheduled early.

Own-brand and private label. If you place a product on the market under your own name, you are the economic operator, whoever manufactured it. Retailers with private label ranges frequently underestimate this.

Intra-group transfers. "Placed on the market" is about first making available in the EU, so group structures with a manufacturing entity in one country and a sales entity in another need to identify which entity carries the obligation. That decision also determines which entity registers, as set out in registration starts with the company.

The practical test

Ask two questions rather than one.

Am I the economic operator placing a product on the EU market? That determines your legal obligation.

Do my customers need my data for theirs? That determines when the work starts, and for most suppliers the answer to the second arrives years before the first would have.

Sources

• European Commission, *Digital Product Passport: FAQ*, January 2026 update, question 11.
• Regulation (EU) 2024/1781 (ESPR).