Short answer: who is the provider?
In texts about the digital product passport, you may encounter the term 'provider' alongside more familiar terms such as manufacturer, importer and distributor. A provider is, in short, the party that actually makes a product available on the market to the next link in the chain or to the end user. This can be the manufacturer itself, but equally well an importer, a wholesaler, an online shop or a store that resells the product.
It is therefore a role, not a type of business. One and the same enterprise can be a manufacturer for one product and a provider for another product, simply because it purchases that second product from another party and resells it. Which term exactly applies and which obligations are associated with it varies per product category and is set out in the regulation and the supplementary rules established for each category.
Provider versus manufacturer, importer and distributor
The regulation works with a chain of roles. The manufacturer is the one who designs the product or has it made and brings it to the market for the first time under its name. The importer brings a product from outside the EU and places it on the market here for the first time. The distributor, and in some texts thus the provider, comes next: that party has not made the product or imported it for the first time, but does make it available to the next link in the chain or to the consumer.
This distinction determines who must supply which part of the information in the passport and who must ensure that the passport exists and is correct. A manufacturer or importer is usually responsible for having the passport drawn up itself. A provider further down the chain usually has a different task: to check that the passport is present, legible and linked to the correct product before the product is resold.
Why this distinction may be relevant to you
If you purchase products from another manufacturer and sell them under your own label or through your own store, you may find yourself in the role of provider without having named it as such. The same applies to companies that source products from abroad and place them on the market in the Netherlands: depending on the exact arrangement, that role may be closer to importer or closer to distributor. That distinction is relevant because the obligations are not identical for each role.
This is precisely the detail where it often goes wrong in practice: companies think that the passport is only a matter for the manufacturer, while whoever makes the product available after that also has a task. That task is usually lighter than drawing up the passport, but is not optional. In the knowledge base per role and product category this distinction is worked out further for each situation.
Passing on the passport, not drawing it up again
A provider who resells a product with an existing passport does not need to rebuild that passport. The QR code and the underlying data remain in principle the same, even if the product passes through multiple links in the chain to reach the end user. What does change is that each link in the chain has an interest in keeping the link between product and passport intact, especially if products are repackaged, combined into a set, or brought to the market under a different brand.
What if you fulfil multiple roles at the same time?
It is common for a company to be a manufacturer for one product and a distributor for another, or for a company to be both an importer and a distributor at the same time because it both imports and sells directly to consumers. The regulation itself links the obligation to the role that applies at that moment, not to the company as a whole. This means that a careful inventory per product line is useful: what role do you have with this specific product, and what follows from that.
Whether a specific situation in your case falls under one role or the other, and which obligations are precisely associated with it, is something for which ultimately the official text and, in case of doubt, a lawyer or the competent supervisory authority will provide clarification. If you want to get an impression first without having to figure everything out yourself, you can get a first indication in a few questions of where your products and your role in that stand.
Where you can look this up for your own products
The precise definition of the roles in the chain is in the regulation itself and, per product group, in the supplementary delegated rules established by the European Commission. For frequently asked questions about roles and obligations, you can also view the collected answers on the frequently asked questions page. There is also information per subject on where the source can be found in the official text, so that you can read that yourself.
If an initial check suggests that you are likely to be considered a distributor for one or more products, it is a logical next step to look at which data applies and how best to record it. Feel free to take the free quick-scan, or browse through the other topics in the knowledge base to see what is relevant for your situation.