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Operator role

DPP Economic Operator Role Checker

See which ESPR operator role may fit, and which Digital Product Passport responsibilities that role can trigger. This is not a readiness score.

Organisation activity

What this checker does

It screens one organisation against the ESPR operator ideas: manufacturer, importer, authorised representative, distributor, dealer, fulfilment service provider, and online marketplace. ESPR is the framework. A DPP becomes concrete only through the applicable delegated act or other product legislation. The existing passport checker looks at product information. This page looks at role.

How roles are separated

A manufacturer makes the product or has it made and sells it under its own name. An importer is established in the EU and is the first to place a non-EU product on that market. An authorised representative needs a written mandate, and the mandate does not by itself assign passport creation. A distributor or dealer who comes later checks what is already placed. A fulfilment provider does not become the creator. A marketplace can have an access or display role, especially in distance selling, without being the creator.

Examples

  • Own-name product: possible manufacturer, with creation, data, and registration still depending on the product rule.
  • Non-EU product, first placed by an EU-established organisation: possible importer, with verification and a placing duty.
  • Later availability after another EU operator placed the product: possible distributor, checking marking, documents, and passport access.
  • Online marketplace with distance selling: possible access or display role before the customer is bound. Not the passport creator.

How it works

Answer whether a DPP requirement applies, select the closed activities, then answer EU establishment, own brand, non-EU origin, first placement, later availability, mandate, fulfilment, distance selling, marketplace, and control of the passport data. Unknown facts that would change the role stay on review. Conflicting first-placer and later-availability answers stay on review.

Responsibilities

Creation or data, registration, verification, customer access or display, and the handoff of a digital copy or unique product identifier are listed separately. One marketplace answer never assigns creation by itself.

Official sources

The links are Regulation (EU) 2024/1781 for Articles 2, 9, 10, 11, and 27-30, and the Commission page on Digital Product Passport economic operators. A later delegated act is a reason to review this ruleset. It does not update the result by itself.

Limitations

Operational screening, not legal advice and not a legal role assignment. A role result does not mean a DPP is already mandatory, that every data field applies, or that the same duty exists for every product group. No certification or exemption is given.