In short
The manufacturer owns the EU Digital Product Passport. When the manufacturer sits outside the EU, the obligation falls on the importer placing the product on the EU market. So a non-EU brand selling into Europe owns its passports — not its factory — and is fully in scope.
The party that places the product on the EU market holds the passport obligation. For EU-made goods that’s the manufacturer; for imported goods it’s the importer. Many brands assume the factory will “handle the QR code” — but the legal responsibility, and the liability, sits with the brand or importer.
| Scenario | Who owns the passport |
|---|---|
| EU manufacturer | The manufacturer |
| Non-EU manufacturer, EU importer | The importer |
| Brand using contract manufacturers | The brand/importer placing it on the market |