Economic Operator
Definition
An economic operator is any natural or legal person involved in making a product available on the EU market. Under ESPR and related regulations, economic operators have specific compliance obligations — including the creation, maintenance, and accessibility of Digital Product Passports.
Who qualifies as an economic operator
| Role | Definition | DPP obligation | |------|-----------|----------------| | Manufacturer | Designs and produces the product (or has it produced under their name) | Creates the DPP and registers it | | Importer | First entity to place a non-EU product on the EU market | Ensures DPP exists and is valid; becomes responsible if manufacturer is outside EU | | Authorised representative | Entity designated by a non-EU manufacturer to act on their behalf | Ensures compliance documentation is available | | Distributor | Makes products available on the market (does not manufacture or import) | Verifies DPP exists; does not alter it | | Fulfilment service provider | Warehousing, packaging, shipping for online sellers | Must verify DPP compliance for products they handle |
Why importers carry significant risk
Under ESPR, when a product's manufacturer is outside the EU, the importer becomes the responsible entity. This means:
- The importer must ensure the product has a valid DPP before placing it on the market
- If the DPP is missing, incomplete, or inaccurate, the importer faces the penalties — not the overseas manufacturer
- Customs can block products at the border if the DPP is not registered in the EU DPP Registry
This is a significant shift. Many importers are not yet aware that DPP liability falls on them.
Related terms
- Digital Product Passport (DPP) — what economic operators must create and maintain
- ESPR — the regulation defining economic operator obligations