ESPR Article 12 explained: unique identifiers for the DPP

ESPR Article 12: Using Unique Identifiers for Operators and Facilities

A core requirement of the ESPR is that companies must be able to track and identify every actor involved in a product’s lifecycle. Article 12 establishes how this works by requiring the use of unique identifiers—standardised codes that pinpoint specific operators (businesses, manufacturers, distributors) and facilities (factories, warehouses, recycling centres) across the European Union and beyond.

If you’re placing a product on the EU market and creating or updating a Digital Product Passport, you need to ensure that every organisation and location mentioned in your product’s journey is assigned a unique identifier that meets EU standards. This isn’t optional; it’s a foundational requirement for compliance.

What Unique Identifiers Are and Why They Matter

A unique identifier is a standardised code or reference number that distinguishes one operator or facility from another—globally, not just within your company or country. Think of it as an official digital “address” for a business or location. Instead of referring to “Factory XYZ in Poland” in free text, you’d use a standardised identifier like a DUNS number, a facility registry code, or another approved format.

These identifiers must comply with technical standards listed in Annex III of the ESPR, or equivalent European or international standards that deliver the same level of reliability and interoperability. The key requirement is that identifiers must be:

• Reliable and verifiable: They must be issued by a trustworthy authority and capable of being checked independently.
• Globally unique: The same identifier should refer to the same operator or facility everywhere in the world, eliminating confusion and duplication.
• Interoperable: They must work seamlessly across different digital systems, platforms, and Digital Product Passport implementations.
• Technologically neutral: The rules governing them must not lock companies into a specific technology or format, allowing flexibility as systems evolve.

Who Is Responsible for Obtaining Identifiers

The company creating or updating the Digital Product Passport bears the responsibility for ensuring that operators and facilities have unique identifiers. This is typically the manufacturer or the party placing the product on the market, though responsibility can rest with whoever is responsible for compiling passport data at each stage of the supply chain.

If an operator or facility already has a unique identifier issued by a recognised agency, you simply use that existing identifier. The work is straightforward in this case.

If no identifier exists, you have two options:

• Request one from an issuing agency: You can ask a designated issuing body to create and assign a unique identifier to the operator or facility on their behalf. This is typically the formal route and involves contacting the appropriate authority (which may vary by country or sector).
• Create one yourself: The EU will establish rules allowing companies to generate their own unique identifiers under certain conditions. The Commission will publish detailed guidance on how to do this while maintaining reliability, verifiability, and global uniqueness.

In either case, once the identifier is issued or created, you must provide the details to the relevant operator or facility so they are aware of how they’re being identified in the supply chain.

The Verification Requirement

Before requesting a new identifier on behalf of an operator or facility, you must first confirm that one doesn’t already exist. This prevents duplication and ensures that the same organisation isn’t assigned multiple different identifiers across the system. The verification process will be clarified in the implementing rules the EU Commission is developing, but the principle is clear: always check first.

How This Connects to the Broader ESPR Framework

Unique identifiers are the backbone of the Digital Product Passport system. Without them, it would be impossible to create reliable, auditable records of where a product came from, who handled it, and where it might go for reuse or recycling. They enable traceability, support compliance verification, and make data shareable across different systems and stakeholders.

The identifier requirement also supports other ESPR obligations, such as those in Article 8 (information to be included in the passport) and Article 9 (access and portability of passport data). When you provide an identifier, you’re ensuring that the passport data can be linked to trustworthy, verifiable information about that operator or facility.

Practical Implications for Your Business

If your company manufactures products or manages supply chains for the EU market, you should:

• Audit your supply chain: Identify all operators (suppliers, logistics providers, recyclers) and facilities (factories, distribution hubs, treatment plants) involved in your product’s lifecycle.
• Check for existing identifiers: Determine whether these organisations and locations already have approved unique identifiers from recognised issuing agencies.
• Request or create missing identifiers: For those without one, either submit a request to an issuing agency or prepare to create your own once the Commission publishes the technical rules.
• Document and communicate: Maintain records of which identifier corresponds to which operator or facility, and ensure they are informed of their identifier.
• Integrate into your passport system: Ensure your Digital Product Passport platform or process captures and displays these identifiers alongside operator and facility information.

The burden is manageable if you plan ahead. Many operators—especially larger manufacturers and distributors—may already have standard identifiers (such as DUNS numbers or tax registration codes) that meet the ESPR requirements. The challenge lies in mapping your supply chain comprehensively and ensuring consistency across your passport data.

Frequently Asked Questions

Do all operators and facilities need a unique identifier, or only some?

Article 12 applies to all operators and facilities that are included in the Digital Product Passport. The information requirements in other ESPR articles (such as Article 8) specify which actors must be named and tracked. If they appear in the passport, they must have a unique identifier.

What if an operator refuses to provide information needed to request an identifier on their behalf?

The article requires you to request an identifier on their behalf if one doesn’t exist. If an operator is uncooperative, you may face compliance challenges. It’s advisable to establish clear contractual language with suppliers and partners requiring them to support identifier registration as part of your supply chain agreement.

Will I need different identifiers for the same facility in different countries?

No. The requirement for global uniqueness means that a single, standardised identifier should refer to the same facility everywhere. This is the entire point of using EU-compliant identifiers rather than internal or national codes. The system is designed to avoid fragmentation and duplication.

Official text (ESPR Article 12): “unique operator identifiers and unique facility identifiers shall comply with the standards referred to in Annex III” — Regulation (EU) 2024/1781, EUR-Lex

Related: ESPR explained · What is a Digital Product Passport?