Many importers assume that "compliance is the manufacturer's problem". In EU product law, that is a mistake. The moment you bring a product in from outside the EU and place it on the Union market, you, as the importer, become responsible for ensuring that the product conforms — and you must be able to demonstrate this with documentation when authorities inspect.
Why are you responsible?
EU product law distributes responsibility along a chain of economic operators (manufacturer, authorised representative, importer, distributor). The importer is the operator who first places a non-EU product on the Union market — which is why it falls to them to:
- satisfy themselves that the product conforms (CE marking, the relevant regulations);
- ensure the mandatory documentation (declaration of conformity, technical file);
- in future, ensure the Digital Product Passport where it is mandatory.
What does this mean in the DPP era?
As the ESPR and the Battery Regulation make the DPP mandatory, the importer must ensure that the imported product carries a valid, trustworthy Digital Product Passport. In practice this means either:
- the manufacturer produces and hands over the DPP data, which you verify; or
- you have to collect the data and produce the trustworthy DPP yourself.
In practice, data at many overseas manufacturers is incomplete or unstructured — in which case structuring and authentication fall to the importer.
Typical importer risks
- Incomplete supplier data: carbon footprint, recycled content and material composition are not available in a ready format.
- Language and communication gap: the factory is in Asia, the requirement is in the EU.
- Market inspection: if you cannot present documentation, the product can be withdrawn and a fine may follow.
- Greenwashing risk: if you make a green claim (EmpCo), you have to prove that too.
How can you protect yourself?
1. Contractual data clause: write into the supplier contract which data must be supplied, and in what format. 2. Data structuring: structure the supplier data according to the relevant schema (e.g. DIN DKE SPEC 99100). 3. Trustworthy DPP: produce an eIDAS-compliant signed product passport that can be presented during an inspection. 4. Verifiability: make the DPP accessible via a QR code, with access groups.
The Asian bridge
For many importers, the biggest obstacle is communication with the supplier. A partner that offers native-level Chinese communication and EU compliance expertise at the same time significantly reduces both the risk and the preparation time.
Official source: for the details, see Regulation (EU) 2019/1020 on market surveillance on EUR-Lex.
Frequently asked questions
Is the manufacturer's CE marking enough?
Not necessarily. CE is required, but the DPP is a separate, structured, trustworthy data requirement.
What if the manufacturer provides no data?
Importer responsibility does not disappear. The data must be structured and authenticated — which calls for a platform and/or advisory support.
Is a DPP required in the local language?
Consumer-facing content must be available in the language of the market; the DPP platform must support multiple languages.
Importer responsibility cannot be passed on. ReadyPass helps you structure supplier data and produce a trustworthy DPP — with Asian-bridge competence.
Sources: ESPR (EU) 2024/1781; Battery Regulation (EU) 2023/1542; REACH 1907/2006/EC. For information only; not legal advice.
