What does the product passport mean if I import products from outside the EU?
As an importer you are jointly responsible for the passport
Anyone who brings products from outside the EU and places them on the market here is not considered a manufacturer but an importer, and this role carries its own obligations under the ESPR (Regulation (EU) 2024/1781) regarding the digital product passport. The passport must exist and be correct before the product enters the EU market, and customs can check this upon import. This means an importer cannot rely on "the manufacturer will handle it" — there is a separate duty of care, and if customs has doubts about a shipment, they can request the passport before the goods are released.
Who this applies to, and what it does not
These obligations apply to anyone acting as an importer within the meaning of the ESPR: a party established in the EU that places a product from a country outside the EU on the EU market for the first time. A EU manufacturer producing goods itself is subject to different, separate obligations as a manufacturer — these do not fall within this scope. Similarly, for a party that merely allows goods to pass through to a destination outside the EU without placing them on the market here, the situation is different: transit is not the same as placing on the market.
More importantly, the distinction must be made at product level. The ESPR is a framework regulation: it sets out the rules, but which product groups actually need a product passport, with what data and from when, is worked out separately for each product group. As long as no specific rules for a particular product group are in force, there is no concrete passport obligation to comply with — the obligations of Article 29 and the inspection powers of Article 15 only become relevant once this has been arranged for the relevant product category.
When this takes effect varies by product group
There is no single date that applies to all product groups at once. The ESPR itself establishes the system — including the importer's role and customs inspection — but the actual implementation date and precise requirements are determined separately for each product group through separate regulations. For some product groups this process is further along than for others. Anyone wanting to know whether, and from when, this applies to a specific product therefore looks not only at the ESPR, but at the product group-specific regulation that will apply to it. Until such a regulation applies to a product group, the existing market surveillance and customs rules continue to apply as they did before the introduction of the product passport.
How to approach this in practice
The first step is to check whether the product group being imported already falls or will fall under a passport obligation, and if so, from when — this is stated in the product group-specific regulation, not in the ESPR itself. If this is the case, the next step is to contact the manufacturer or supplier outside the EU: they are typically responsible for having the passport drawn up and the associated data prepared. For the importer it is relevant to be able to demonstrate that the passport actually exists, that it is accessible via the QR code on or with the product, and that the data in it corresponds with what is actually being imported.
Additionally, this may involve adding your own name and contact details as the importer, so it is clear who placed the product on the EU market. In practice this means an importer would be well advised to establish such arrangements with the supplier when purchasing, rather than discovering this only when passing through customs. Documentation showing that the passport has been checked and is correct is useful to have on hand — particularly because customs can inspect this upon import.
What this is based on
The obligations for importers regarding the digital product passport are set out in Article 29 of the ESPR (Regulation (EU) 2024/1781). The authority of customs to control this upon import from outside the EU is set out in Article 15 of the same regulation. Both articles form part of the general framework of the ESPR; the concrete implementation per product category — which data, which format, and from when — follows from supplementary regulations per product category.
What to do now
Determine which product category the imported products fall under and check whether specific regulations with a product passport obligation are already in force or under development for that category. In case of doubt, contact the manufacturer or supplier outside the EU who prepares the passport and the data it contains, and document how and where that passport remains accessible after import. Consult the exact text of the obligations in Article 29 and Article 15 of the ESPR, and monitor product category-specific regulations for the actual entry into force date.
Where this is based on
- Regulation (EU) 2024/1781 (ESPR), Article 15 (customs controls relating to the digital product passport)
- Regulation (EU) 2024/1781 (ESPR), Article 29 (obligations of importers)
The regulation itself is on EUR-Lex. We provide references for each claim; you do not have to take our word for it.
What you must do concretely
When an importer brings products from outside the EU onto the European market, it is not a pass-through for the ESPR but an importer — with its own set of obligations that is independent of what the manufacturer in the country of origin does or does not arrange. The product passport does not change the usual role of importer as a result, but it does make that role visible and controllable in a new way: at customs, at the gate.
What is expected of you
Verify that the passport exists before the product is imported
Article 29 of the ESPR (Regulation (EU) 2024/1781) places on the importer the obligation to check whether the manufacturer outside the EU has the required conformity and documentation in order, including the digital product passport where that is mandatory for the product category. For a company with 10 to 100 employees, this means that the purchasing department — often the same people who already check CE marking and declarations of conformity — gets an additional control point: is there a passport, is it linked to the correct product, and is the QR code or other data carrier present on the product or packaging. For those who want to know, which data must I request from my product supplier, there is a point of reference that applies equally to a manufacturer outside the EU as to a supplier within the EU.
Act yourself if the passport is missing or incorrect
Where there is often still room with a European supplier to jointly close a gap, the responsibility lies more heavily with the importer itself when importing from outside the EU. If a product is not accompanied by the required passport, or if the passport does not match the product, then it is up to the importer to act on this before the product is placed on the market in the EU. For a mid-sized company, this means there must be a fixed procedure for what happens when a passport is missing or defective — not something that is sorted out ad hoc by whoever has time for each shipment.
State your own data on the passport
Article 29 also requires the importer to make its own name, registered trade name or trademark and contact details known in relation to the product — something that in practice runs via the product passport or accompanying documentation. This is not a matter of 'the manufacturer has already created the passport, so we are done': the importer's details must be there correctly and completely, and that requires coordination with the manufacturer over who fills in and manages which part of the passport.
Cooperate with customs checks on the passport
Article 15 of the ESPR provides that customs authorities at the point of entry of products from third countries can check whether the digital product passport is present and accessible, in particular via the data carrier on the product. For an importer, this means it is not enough to have the passport somewhere in a system — it must be actually retrievable via the QR code or similar carrier on the product itself or the packaging at the time of import. A company that receives shipments in a port or airport would be well advised to have this tested before shipment, not only when the shipment is already with customs.
Where things go wrong in practice
A first recurring problem: the manufacturer outside the EU supplies a passport, but that passport is linked to a generic product version while the importer imports a specific variant — different colour, different power output, different composition. The QR code works, but points to the wrong data.
A second situation: the importer assumes that 'the supplier will handle this' because that is often how it feels with CE marking, and discovers during a customs check that no passport has been created at all for the product category in question. At that point, the shipment is already there, and working out who should have delivered the passport is not an answer to the question the customs asks.
A third case: a passport exists, but the importer data in it has not been updated following a change of importer or intermediary — the passport still names a previous party as responsible. This touches on a question that arises more broadly when changing suppliers: I am changing suppliers must the product passport be adjusted concerns that situation within the EU, but the core — that a passport must remain accurate regarding who is actually responsible — applies equally to an importer switching from a manufacturer outside the EU.
A fourth situation: the same product code is sourced from two different manufacturers outside the EU, and the importer assumes that one passport template suffices for both, while the underlying composition or origin of components differs. This touches on the question that also arises with I use multiple suppliers for the same component how does the passport work in that case — the passport follows the product as it is actually composed, not the product name on the invoice.
A fifth recurring point: the manufacturer outside the EU is unwilling to share all underlying data for reasons of competition, and the importer does not know how to reach agreements on this without jeopardizing the business relationship.
What you can document
- A fixed checklist upon receipt of each shipment from outside the EU: is the passport present, does the data carrier work, do the product code and variant match what is actually being imported.
- Agreements with the manufacturer outside the EU on who prepares the passport, who adds the importer data and who keeps it current — comparable to what How do I document the provision of passport data in my purchase contract describes for suppliers in general, and equally relevant in a contract with a party outside the EU.
- A procedure for verifying the accuracy of received data before the first import of a new product line, using as a starting point How do I check whether my supplier's data are correct.
- A documented procedure for the event that a shipment arrives without a valid passport: who is notified, what step follows, and what documentation is kept in this regard.
- If relevant, a confidentiality agreement with the manufacturer outside the EU regarding the underlying data needed to compile the passport, as described in can I request a confidentiality agreement from my supplier regarding passport data.
- An overview per product group of whether and from what point the passport is mandatory for it, as background to the import decision — see When does the product passport become mandatory for products.
This is not legal advice. This page provides general information about the regulations that this platform concerns. We do not know your situation. If you are in doubt about your own case, consult a lawyer or the competent supervisory authority.
Written with AI on the basis of the sources above, checked by a human on 2026-08-22. Is something incorrect? Let us know — corrections are given priority.