DPP for importers in the EU: You carry the responsibility, even if you didn't make the product

If you import goods from Turkey, China or India and sell them on the European market, we have some important news for you: responsibility for the Digital Product Passport is yours. Not the manufacturer's in Shanghai. Not the freight forwarder's in Hamburg. Yours.

Many importers reassure themselves with the thought that if the manufacturer isn't based in the EU, it doesn't fall under European regulations. This is a dangerously mistaken assumption that can lead to shipments held at customs, fines and loss of market access.

Who is the economic operator under ESPR?

The Ecodesign for Sustainable Products Regulation (ESPR) defines a clear hierarchy of responsibility. At the top sits the manufacturer. If it's based outside the EU, responsibility automatically falls on the importer — the person or company that places the product on the EU market for the first time. If the importer, too, is merely an intermediary, responsibility may pass to the authorised representative.

In practical terms: if you're a company registered in the EU importing products from third countries — you are the economic operator and you carry full legal responsibility for the DPP.

What exactly should you require from foreign suppliers?

Before DPP becomes mandatory, now is the moment to negotiate with your suppliers. Here's the data you'll need for a typical non-battery product:

• A full list of materials with exact percentages (Bill of Materials)
• Information on hazardous substances (SVHC substances under the REACH regulation)
• Carbon footprint of the product and its packaging
• Country of manufacture and factory details (address, certificates)
• Disassembly and recycling instructions
• Quality and safety certificates (CE, ISO, etc.)

How to build DPP requirements into supplier contracts?

Standard import contracts need to be updated with new clauses. The key points are:

• The supplier's obligation to provide structured data in a defined format (JSON, XML) with every shipment
• The importer's right to conduct audits or hire third parties to verify the data
• Penalties for providing false or incomplete information
• An update clause — if the formulation or materials change, the supplier is obliged to notify you immediately

Specific risks for different import categories

Not all products are equally risky from a DPP standpoint. Here's a quick risk map:

• Textiles and clothing from Asia: High risk — the origin of the cotton and dyes is hard to trace. Require OEKO-TEX or GOTS certificates
• Electronics from China: High risk — hazardous substances (RoHS), rare metals. CE declarations and a material list are mandatory
• Furniture from Turkey: Medium risk — focus on the origin of the timber and the chemistry of the coatings
• Food supplements and cosmetics: Very high risk — they directly affect health. Full traceability of ingredients is mandatory

Customs as the first line of control

With the introduction of DPP, customs control will change fundamentally. At customs clearance the importer will supply the registration identifier from the EU’s central DPP registry, and the check will become automatic once the registry is connected to the EU customs system. A shipment without a DPP, or with an invalid one, may be held or refused release until the matter is clarified, and a non-compliant product may not be placed on the EU market.

Conclusion

For European importers, DPP is not an abstract European concept — it's a real business risk with concrete financial consequences. But it's also a huge opportunity: importers who build strict data standards with their suppliers will have more reliable, transparent and sustainable supply chains. In an era when greenwashing is penalised, honesty is the best business strategy.