What documents do you need for the digital product passport if you are an importer?
As an importer, you do not retrieve the data for the digital product passport yourself from your own factory, but from a manufacturer outside the EU. This makes the list of required documents slightly different from that of a manufacturer who produces and measures everything themselves. In any case, you need the technical documentation of the product, the data on materials, repair and energy consumption that the regulation requests for the relevant product group, a declaration of conformity, your own importer details, and a binding arrangement with the manufacturer regarding the provision and maintenance of that information.
The detail that matters most in this situation is that last point: the arrangement with the manufacturer. An importer is often seen in the supply chain as the party responsible for the passport, while the underlying data lies with someone else. Without a binding arrangement regarding provision and updating, you are left empty-handed if anything changes about the product or the repair information.
What is on the list and why exactly that document counts
The technical documentation forms the core: data on the materials used, the lifespan, the repair possibilities and, depending on the product group, the energy consumption. This data differs per sub-category of electronics or ICT equipment, because the delegated acts that set the precise requirements are published per product group. Additionally, there must be a declaration of conformity, which states that the product complies with the applicable requirements. Your own details as an importer — name, address, and the role you fulfil in the supply chain — complete the picture, together with the unique identification that is linked to the QR data carrier.
For each of these documents, you must obtain them from somewhere. For a manufacturer, that is internal; for an importer, it is from the manufacturer or supplier outside the EU. Who exactly fulfils which role, and what that means for your obligations, you can read in more detail in the knowledge base by topic.
The detail that weighs most heavily for importers
The passport must remain up to date for ten years. A manufacturer who produces themselves knows when a component changes. An importer depends on signals from the manufacturer for this, and those signals do not come automatically. That is why the most important question is not only which documents you need now, but also how you ensure that you still receive them in three years if something about the product changes.
The regulation distinguishes roles in the supply chain, and supervisors look at who has provided which data and on what basis. This is no reason for concern, but it is a reason not to leave the arrangement with your manufacturer or supplier without obligation. A written arrangement regarding delivery, updating and liability for incorrect data should be standard in the procurement file, just as it already happens now with CE marking and declarations of conformity.
What this means for the conversation with your supplier
It is advisable to have this conversation not only once the obligation for your product group is established, but to ask about it now already: what data can the manufacturer provide, in what form, and who reports if anything changes. The same question also comes up with the AI Regulation and with the General Product Safety Regulation, so it is efficient to establish this properly in one go in the supplier contract.
Whether your products are already subject to a concrete obligation, and which data that entails, varies by product group and has not yet been determined for every category. You can get an initial indication of where you stand for your own product group by answering a few questions about your situation. You can read how we compile the information on elektropas.com and what it is based on at the page about our working method.
Where you can already start now
Even if the exact date for your product group is not yet fixed, you can already map out which documentation your manufacturer or supplier can provide and which they cannot. This prevents you from having to reconstruct what is missing afterwards. For specific questions about your own contract or liability as an importer, it is advisable to consult a lawyer; we describe the regulation, but do not provide legal advice on your individual situation.
Would you like to clearly see which documents are relevant for your product group and which questions often come up about them? Do the free quick-scan or browse through the most frequently asked questions about the digital product passport to see what challenges other entrepreneurs in the same situation are facing.