Not necessarily. The passport data can be hosted by the manufacturer itself or entrusted to a service provider. The key is not the system, but whether you can produce that data—and most of the data needs to be collected from upstream supply chain partners, which is where the time investment is.
Full explanation and HS code list: https://patisco.com/zh/eu-check/digital-product-passport Check which EU regulations apply to your products using HS codes: https://patisco.com/zh/eu-check