who must sign that the product passport is correct

The manufacturer is responsible for accuracy, not a separate signature

The ESPR does not work with a signature under the digital product passport, but with a responsibility that rests with the manufacturer. Article 27 of the ESPR (Regulation (EU) 2024/1781) establishes that the manufacturer ensures that the product and the associated information — including the digital product passport — comply with the requirements. This is not a signature such as on a declaration or contract, but a legal obligation: the manufacturer is the party responsible for the accuracy of the data in the passport, for as long as the product is on the market.

For whom this applies, and when someone else comes into play

This responsibility rests in the first place with the manufacturer as indicated in Article 27 of the ESPR: the party that designs, manufactures or places the product on the market under its own name. Who exactly qualifies as a manufacturer and who as an importer is not always straightforward — especially in the case of procurement outside the EU or sale under a private brand. For those situations, the distinction between who is responsible for the digital product passport and the question whether someone qualifies as an importer or manufacturer is decisive for the question of who is concretely involved here. Article 29 of the ESPR regulates the position of the importer: that party must check that the manufacturer has fulfilled its obligations, including the existence of a correct digital product passport, before the product is placed on the EU market. That is a control obligation, not a separate signature of the content. A distributor or trader is further removed from the content and has its own, more limited role in it.

What does not fall under this: a physical or digital signature of a person within the company, such as in a declaration of conformity which is often signed with name and job title. The digital product passport itself is primarily a data carrier — a collection of information accessible via the QR code — and not a document that requires a signature. The responsibility lies with the organisation designated as a manufacturer or importer, not at a signing moment by an individual.

The obligation already exists, the implementation per product group does not yet

Article 27 and Article 29 of the ESPR apply as a general framework once the Regulation takes effect, but the specific requirements for the digital product passport for electrical and ICT equipment follow per product category from delegated acts. For this target group, it has not yet been determined on what date those acts will be published; the ESPR work plan mentions a period from 2027 for the development of category-specific rules, but a fixed date for electrical and ICT equipment is not yet set. Until that act is in place, the general principle of Article 27 and 29 applies — that the manufacturer is responsible and the importer must check — but the precise content of the passport, and with it any additional form requirements, is not yet fixed. Once the delegated act for this category has been published, this will be supplemented here with the date that then applies.

What an entrepreneur does with this

Anyone wondering who in their own organisation "must sign" looks in practice first at their own role: manufacturer, importer or something in between, such as when selling under a private brand. For those selling private label electronics this question is not always straightforward, because the brand on the product does not automatically determine who the legal manufacturer is. It is then important to establish who actually supplies and manages the data for the passport: that is the party bearing the responsibility under Article 27, even if an external platform — such as elektropas.com — compiles and hosts the passport on the basis of the supplied data. For a manufacturer outside the EU, part of the practical handling shifts to the importer, who must verify under Article 29 that the passport exists and is correct before the product reaches the EU market. Finally, it is worthwhile to consider what happens if there is an error in the data after all, and who is accountable for it — that is a separate question distinct from who initially supplied the data.

The legal basis: Articles 27, 29 and 9 of the ESPR

The obligation for the manufacturer to ensure conformity of the product and the information about it follows from Article 27 of the ESPR (Regulation (EU) 2024/1781). The importer's verification obligation is set out in Article 29 of the same regulation. Article 9 describes the digital product passport itself: what it is, what function it serves, and how it is linked to the product — without a signature requirement. The concrete, product group-specific implementation for electronics and ICT will follow from a delegated act that has not yet been published.

Those wishing to know how this responsibility plays out in their own supply chain can read further about the position as distributor or trader, about the situation where the manufacturer is located outside the EU, or about what must be arranged in the case of resale of electronics within the EU. Once the delegated act for electronics and ICT is published, this page will be updated with the then applicable date and any additional requirements for recording conformity.

What this is based on

The regulation itself is on EUR-Lex. We provide references per statement; you do not have to take our word for it.

What you must concretely do

What is expected of you

The question "who signs the product passport" is actually about something different: who bears the responsibility that the data in it are correct. With the digital product passport there is no signature in the classical sense, such as on an EU declaration of conformity with a name and a signature underneath. Article 9 of the ESPR (Regulation (EU) 2024/1781) describes the passport as a dataset linked to the product via a data carrier, not as a signed document. The responsibility lies with the party that supplies the data and ensures its accuracy — and that is, according to Article 27 of the ESPR, the manufacturer.

The manufacturer compiles the data and bears the responsibility

Article 27 of the ESPR places the obligation on the manufacturer to supply the information for the product passport correctly and in full. For a company with 10 to 100 employees that itself manufactures or has products manufactured under its own brand, this means that the technical department, the quality service or whoever manages the product documentation is the source of the data that ultimately appear in the passport. Who specifically within the company releases that data for publication is an internal matter — the ESPR does not prescribe a job title. What is certain: the manufacturer is the party accountable to the supervisory authority for ensuring that the data correspond to the product. Anyone uncertain whether that role applies to their own company will find a more detailed explanation on who is responsible for the product passport of electronics.

The importer verifies, but does not draw up itself

Article 29 of the ESPR describes the obligations of importers: they must verify that the manufacturer has fulfilled its obligations, including the existence of a product passport. For an importer of electronics from outside the EU, this means a verification role, not a compilation one. The importer does not sign anything, but must be able to demonstrate that it has verified whether the passport is present and accessible. For companies that are uncertain whether they should be classified as a manufacturer or as an importer in a given situation, there is a separate explanation on am I an importer or manufacturer according to the ESPR.

Whoever sells under its own brand takes on the manufacturer role

A company that purchases electronics from a third party and places them on the market under its own brand name is treated as a manufacturer for the purposes of Article 27 of the ESPR. This is relevant to the question of who provides the data: not the original producer, but the party whose brand appears on the product. This situation is common with private label electronics and white goods, and is explained in more detail on selling under my own brand — what obligations do I have and on I sell private label electronics, what are my obligations.

Where things go wrong in practice

A few situations regularly come up with companies that are working with the product passport.

The technical department provides data without anyone bearing ultimate responsibility. Data comes from different departments — procurement, R&D, quality — and no one checks the coherence before the passport goes live.

An importer assumes that the manufacturer has taken care of the passport. Article 29 of the ESPR requires verification, not an assumption. Without that verification, it cannot be demonstrated that the importer has fulfilled its own obligation.

With private label, the manufacturer role is not recognised. A company thinks that it is "only selling" while its own brand is on the product, and the manufacturer role under Article 27 of the ESPR therefore actually lies with them.

Changes to the product are not reflected in the passport. A product modification — different material, different supplier of a component — is processed technically, but no one thinks about the data already in the passport.

Uncertainty about who within the company "signs". Because there is no physical signature, some companies think that there is no need to designate an internal responsible person either. This makes it difficult for them to quickly demonstrate to a regulator who provided and verified the data.

What you can document

An internal designation of who approves the data for the product passport, with name and function, so that in the event of an external enquiry it is immediately clear who was responsible for the latest version.
An overview of the sources per data field — which department or which document provided the information on materials, repair data or origin.
A file in which communication with the manufacturer or importer is recorded, in particular for procurement outside the EU. See also the explanation on my manufacturer is outside the European Union — who arranges the product passport then.
A procedure for updating the passport when the product changes, including who signals the change and who carries out the modification.
An overview of roles in resale within the EU, especially when a product reaches the end user through multiple links; this aligns with the situation described on I buy electronics in another EU country and resell them.
Documentation of who is liable in case of an error in the data, agreed internally between manufacturer, importer and any private label party, with reference to the more detailed explanation on who is liable if there is an error in the product passport.

Elektropas compiles the passport on the basis of the data provided by the manufacturer or importer. The responsibility for the accuracy of that data remains, even after publication via the platform, with the party that provided it.

This is not legal advice. This page provides general information about the regulations that this platform covers. We are not familiar with your situation. If you are in doubt about your own case, consult a lawyer or the competent supervisory authority.

Written with AI based on the sources above, checked by a human on 2026-09-05. Is something not correct? Let us know — corrections take priority.