Frequently Asked Questions

The DPP is a digital record, accessed through a data carrier such as a QR code on the product, containing structured information on a product’s composition, origin, durability, repairability, recycled content, and environmental footprint. It is mandated by the Ecodesign for Sustainable Products Regulation (EU) 2024/1781 (ESPR) and, for batteries, by the Battery Regulation (EU) 2023/1542.

No. The DPP phases in product group by product group. Each group gets its own delegated act defining the exact data requirements, and compliance typically applies about 18 months after that act is adopted. Your deadline depends entirely on what you sell.

Based on the adopted ESPR Working Plan 2025–2030 and the Battery Regulation, the current planning timeline is:

Energy-related groups (dishwashers, fridges/freezers, EV chargers, electric motors) follow their own delegated acts in 2026–2028. Footwear, detergents, paints, and chemicals are under feasibility study. Expected dates reflect the Commission’s published Working Plan and may shift; adopted dates are fixed in law. Last verified July 2026.

No. The infrastructure that all DPPs must use is going live now: the first CEN/CENELEC (JTC 24) technical standards were published in May 2026 and the EU central DPP registry is expected from 19 July 2026. Once your delegated act is adopted, the ~18-month window must cover data collection, supplier engagement, system integration, and verification. History shows adoption dates can slip, but compliance windows do not get extended — preparation time is the only advantage you control.

Yes. Any product placed on the EU market must comply with the DPP requirements for its product group, regardless of where the manufacturer is established — including sales through marketplaces and direct-to-consumer channels. Non-EU manufacturers will typically also need an EU-established responsible actor, which is where our Authorised Representative service comes in.

The exact data set is defined per product group in its delegated act. Common elements include: unique product identifier, materials and substances of concern, recycled content, durability and repairability information, carbon/environmental footprint, supply-chain due diligence data, and end-of-life instructions. We map your existing data against the applicable requirements and close the gaps before the deadline.

An Authorised Representative (AR) is a natural or legal person established in the EU who holds a written mandate from a non-EU manufacturer to act on their behalf in relation to specified EU compliance obligations. The two key legal bases are Article 4 of Regulation (EU) 2019/1020 (market surveillance — CE-marked products) and Article 16 of Regulation (EU) 2023/988 (GPSR — general consumer products).

If you are a non-EU manufacturer and there is no EU-established importer or fulfilment service provider taking responsibility for your product, then yes — a product covered by Regulation 2019/1020 Article 4 or GPSR Article 16 may not be placed on the EU market without an EU responsible economic operator. This applies with full force to online and direct-to-consumer sales, where no importer exists in the chain.

The AR keeps your declaration of conformity and technical documentation at the disposal of authorities, provides information and documentation to market surveillance authorities on reasoned request, informs authorities of dangerous products, cooperates on corrective actions, and — under the GPSR — verifies that required safety information accompanies the product. The AR’s name and contact details must appear on the product or its packaging/documentation.

No. The manufacturer remains primarily responsible for product compliance. The AR takes on the specific obligations listed in the written mandate — a defined legal role, not a blanket assumption of liability. That is why our mandates are structured at article level: you know exactly which obligations sit where.

They are alternative EU “responsible economic operators”. An importer physically places goods on the market and takes on its own set of duties; a fulfilment service provider stores and dispatches goods; an AR acts purely under mandate. For direct-to-consumer models without an EU importer, the AR is usually the correct — and only — option.

Once we have reviewed your technical documentation and agreed scope, a mandate is typically executed within days. Product labelling updates (adding our details as your AR) are usually the longest lead-time item. Contact us with your product list and target timeline.