An independent third-party authorised by the economic operator to process DPP data and make it available to entitled actors under ESPR.
Companies can mistake the service provider for the party responsible for the product. The implementation risk is outsourcing hosting or processing while failing to record authorisation, access-right rules, service boundaries, and the economic operator that remains accountable.
ESPR Article 2(32) defines the independent third-party service-provider role. Article 10(4) separately establishes the applicable ESPR back-up-copy duty; Implementing Regulation (EU) 2026/1778 addresses registry metadata, including the provider reference. None of these statements means that the registry stores the complete passport or a universal back-up URL.
Regulation (EU) 2024/1781 establishing a framework for the setting of ecodesign requirements for sustainable products
a natural or legal person that is an independent third-party authorised by the economic operator which places the product on the market or puts it into service and that processes the digital product passport data for that product for the purpose of making such data available to economic operators and other relevant actors with a right to access those data under this Regulation or other Union law;
Reference: Article 2, point 32
Maintain the provider identifier, authorisation record, economic-operator link, product identifier, access-right rule, data-processing log, continuity arrangement and audit trail. For an applicable ESPR digital product passport, Article 10(4) requires the economic operator to make a back-up copy available through a DPP service provider. Keep the registry’s provider reference separate from the hosted passport or its back-up copy; do not extend this ESPR rule automatically to battery passports.
Digital product passport service provider is a passport-service control: service infrastructure, access rights, processing logs, and operator authorisation must be explicit. That prevents a technical provider from being mistaken for the manufacturer, importer, or other economic operator responsible for the product.