A market participant is the collective term that the regulation uses for everyone who plays a role in placing on the market or making available a product: the manufacturer, the importer, the distributor and the authorised representative. It is not an additional obligation in itself, but a classification. Which concrete tasks related to the digital product passport apply depends on which of those roles are applicable to a company — and a company can also fulfil several of them at the same time.
The reason this concept exists is practical. Simply imposing one obligation on 'the company' does not work in a chain that runs from yarn spinner to shop shelf. Therefore, the regulation distinguishes roles and attaches to each role its own package of responsibilities. Who must supply the data, who must maintain the passport and who must be able to demonstrate that a product conforms to what has been stated differs per role.
The roles in brief, without claiming to be exhaustive
The manufacturer is usually whoever designs a product or has it manufactured and places it on the market under their own name. The importer places a product from outside the European Union on the European market for the first time. The distributor is the link thereafter: whoever makes the product available without being a manufacturer or importer, think of a wholesaler or retailer who purchases from an EU manufacturer. The authorised representative is the person whom a market participant outside the EU has designated in writing to carry out tasks on their behalf within the Union.
In addition, there is the concept of producer, which in practice often coincides with manufacturer or importer but is not identical — that distinction is covered in a separate article on this site. For day-to-day practice, it is mainly important to know that the roles do not exclude each other: a company that both designs itself and imports itself is both manufacturer and importer for the same product.
Why the role determines what is expected of you
It is tempting to think that only 'the manufacturer' has to arrange something. That image is not correct. The regulation also imposes obligations on importers and distributors, for example, to check whether the passport is present and whether the information in it corresponds to what is on the product and the accompanying documents. A distributor who places a garment without a passport on the shelves can come into view from supervisory authorities just as much as the party that originally made the product.
This is immediately the detail that comes to the fore most in practice with this concept: companies often underestimate their own role because they do not feel like a 'manufacturer'. An importer who has clothing manufactured under their own brand outside the EU often assumes a position in practice that is close to that of a manufacturer, with the associated responsibilities. Which role precisely applies to a specific situation is something that must be determined by the official text and, where necessary, a lawyer or the competent supervisory authority — that is not a choice that a company can make by calling itself something else.
What this means for the textile passport in practice
For the digital product passport, the role distribution is relevant because it determines who supplies the source data, who is responsible for its accuracy during the term, and who can be held accountable by supervisory authorities in different EU countries. At texpas.eu we compile the passport from the data supplied by the manufacturer or importer; the role of that party does not change anything there, but does determine who must supply and substantiate which data.
Because the delegated act for textiles has not yet been published — the ESPR work plan mentions 2027 as the expected period, with clothing of eighty percent or more textile fibres as the first category — the level of detail at which roles are elaborated may still shift. Once the text is final, that will be added here.
Those who wish to check which role applies to their own situation will find per role an elaborated overview in the knowledge base and can get a first indication in a few questions. For the broader context around what the regulation precisely requires, there is an overview of frequently asked questions, and anyone who wants to know where our information comes from, reads that on the page about how we work.
The free quick-scan provides a first picture of your own situation in a few questions, without requiring an account. Those who prefer to read first will find the short answer and the reference to the official text in the knowledge base per topic.