"Economic operator" is the catch-all term EU product law uses for the actors in a supply chain who carry obligations: manufacturer, authorised representative, importer, distributor, fulfilment service provider, and others. For the Digital Product Passport, the operative question is who is responsible for the passport — and that defaults to whoever places the product on the EU market under their name or trademark. For an EU manufacturer that is the manufacturer; for goods made outside the EU it is usually the importer or an EU-based authorised representative.
This matters because the obligation is not delegable away by a contract clause. The responsible operator must ensure a passport exists, is registered in the EU DPP Registry, stays available for the required period, and reflects accurate, source-backed data — even though much of that data originates upstream with suppliers. Tooling that captures supplier documents and attributes each field to its source is how operators make that accountability tractable; TracePass is built around exactly that gap.
Frequently asked
Is the manufacturer always the responsible economic operator?
Usually, but not always. The obligation falls on whoever places the product on the EU market under their name or trademark. For products made outside the EU, that is typically the importer or an EU-based authorised representative rather than the original manufacturer.
Can an economic operator outsource the DPP obligation?
It can outsource the work of building and hosting the passport, but not the legal accountability. The responsible operator remains liable for the passport's existence, registration and data accuracy regardless of who operates the tooling.
Does a distributor or retailer need to create a DPP?
Generally no — the passport is created by the operator placing the product on the market. But distributors have their own duties (for example verifying a passport is present and correct before selling), and a distributor who modifies a product or sells it under their own brand can become the responsible operator.