What unique identifier does a product passport require?
A persistent unique product identifier, connected to the passport through the data carrier and able to link to it on the web. The regulation ties it, and the operator and facility identifiers beside it, to the ISO/IEC 15459 series until references of harmonised standards are published.
What the text asks for
regulation (EU) 2024/1781 defines a unique product identifier as a unique string of characters for the identification of a product that also enables a web link to the digital product passport. Two requirements in one sentence: it identifies, and it leads somewhere.
Article 10 adds the third: the passport is connected through a data carrier to a persistent unique product identifier. Persistent is the word that constrains a design, since an identifier that changes with a redesign, a supplier or a campaign breaks every carrier already in the field.
The standards it names
Annex III requires the data carrier, the unique product identifier, the operator identifiers and the facility identifiers to comply, where relevant, with the ISO/IEC 15459 series, parts 1 to 6, until the references of harmonised standards are published in the Official Journal. The same annex lists the Global Trade Identification Number, as provided for in ISO/IEC 15459-6, among the data an act may require.
Those are identifier standards rather than carrier ones: they say how an identifier is structured and issued, not which medium carries it. A tag and a printed code satisfy them the same way, which is the point the carrier page makes about the technology neutrality of the text.
The other identifiers
The product identifier is not alone. Annex III also lists unique operator identifiers, for the manufacturer and for other actors in the chain, and unique facility identifiers for the locations involved, and Article 12 governs all three.
It also handles the case where one does not exist yet: the economic operator creating or updating the passport requests the identifier on behalf of the actor concerned, after seeking confirmation from that actor that none exists, and then passes on its full details. A passport therefore pulls identifiers into existence across a supply chain, which is a project rather than a field to fill.
Who issues them
Article 12 empowers the Commission to set rules for the life cycle of identifiers and carriers: rules for organisations wishing to become an issuing agency, and rules for economic operators wishing to create their own identifiers without relying on one. Both routes are contemplated by the text.
The criteria it lists for those rules are worth reading before choosing a scheme: identifiers are to be reliable, verifiable and unique globally, and the Commission is to seek interoperability, take existing technical solutions into account and remain technologically neutral as far as possible. An identifier invented in house has to answer the same requirements as one from an agency.
Frequently asked questions
What makes an identifier persistent?
That it does not change for the product it identifies. A string tied to a campaign, a supplier or a redesign breaks every carrier already in the field.
Which standards apply?
Annex III names the ISO/IEC 15459 series, parts 1 to 6, for the carrier and the identifiers, until references of harmonised standards are published.
Can a company create its own identifiers?
The regulation contemplates it: the Commission is to set rules both for issuing agencies and for operators creating their own identifiers and carriers.
What if a supplier has no operator identifier?
The operator creating the passport requests one on its behalf, after confirming with that actor that none exists, and passes on the details.