The short answer
For many companies, it becomes clear within half a working day to a full working day what role they have in the electronics and ICT supply chain: manufacturer, importer, distributor, or a party that is none of these. This goes quickly when there is one clear supplier, when the product remains under an existing brand, or when your company only resells without making any changes to the product. The regulation that governs the digital product passport distinguishes these roles precisely because each role carries a different responsibility for the data that ends up in the passport.
With composite products, private labels, or a supply chain with multiple intermediaries, the processing time often extends to several days or even a few weeks. First, it must be determined who made, modified, or repackaged which part of the product, and this is not always immediately clear from your own records. Anyone who does not have this readily available must ask their supplier abroad, and that takes time that is not in your own planning.
Why the role matters
The term "operator" is often used in the context of the digital product passport, but it encompasses different roles with different obligations. A manufacturer is generally responsible for the technical data of the product itself. An importer who brings products from outside the EU to the European market is also faced with the question of whether the manufacturer has already provided that data. A distributor who only resells generally has a more limited role, but must still be able to demonstrate that the passport is present. Which role applies to your company thus determines not only who provides the texts and technical details, but also who must be able to provide which documents. In the knowledge base with the roles per situation set out this is elaborated further per type of company.
What determines the processing time
The time needed to establish your own role depends mainly on three things. First, the origin of the product: a product that is purchased ready-made from one manufacturer outside the EU requires a different investigation than a product that is assembled from components from multiple suppliers. Second, the brand under which the product is marketed: as soon as a company puts its own brand or own packaging on an existing product, responsibility often shifts to that party, and that must first be checked. Third, the availability of documentation: is there already an overview of suppliers, manufacturing locations, and any processing, or does that still need to be compiled from invoices and email exchanges.
Where it goes wrong in practice
In practice, companies mainly experience delays with private label products, where a wholesaler or retail chain sells an existing product under its own name. It must then be determined whether only the packaging has been adapted, or whether the product itself has also been changed, as this can change the role. Also with products that come in through multiple channels, for example an importer who purchases from a trading agent who in turn purchases from the manufacturer, determining the actual manufacturer is sometimes more time-consuming than expected. A third stumbling block is uncertainty about who technically modified the product, such as software that was locally installed or components that were replaced for the European market.
When you need more than one week
With a single direct supplier and an unchanged product, the role is usually quick to determine. Once multiple countries, multiple factories, or a changing product composition come into play, it is realistic to allow for a processing time of one to three weeks, especially if suppliers abroad do not respond directly to questions about origin and processing. This is a practical estimate based on common situations, not a fixed deadline from the regulation itself; the regulation itself does not set a deadline for internally determining a role.
What you can establish yourself
It helps to create an overview in advance of each product or product group: who the manufacturer is, through which parties the product enters, and whether anything has been changed along the way. That overview is also useful once the delegated act for your product category is published and the concrete obligations are established. If you are uncertain about your own situation, that is something to put to a lawyer or to the competent supervisory authority; this article describes the regulation in general terms and is not tailored to one specific company.
If you want to quickly get a first impression of where your company stands, you can get a first indication in a few questions. Frequently asked questions about roles and responsibilities in the chain are compiled on the page with answers to questions we often receive, and anyone who wants to know where the information on elektropas.com comes from can read about it on the page on how we compile our information.
The free quick-scan and the topics in the knowledge base give you a first impression without requiring an account. This way you can quickly see whether further investigation is needed for your company, and where you can best start.