Product, operator and facility: three identifiers, not one

Identifiers sound like the most technical part of the digital product passport (DPP) and the easiest to delegate. They are also where a surprising number of projects discover a structural problem late, because the passport needs three different kinds and most product systems are built for one.

Three slots, three lifecycles

The product identifier distinguishes the product, and depending on the delegated act, the model, the batch or the individual item.

The operator identifier identifies the economic operator placing the product on the market. In the GS1 system this is a GLN; companies trading internationally will also hold an EORI number for customs.

The facility identifier identifies the production site. This is the one that breaks naive data models, because it belongs to a site rather than to the company, and a company with four plants has four of them.

The standardisation work under way explicitly covers unique identifiers for products, economic operators and facilities as three distinct categories.

What the regulation does and does not tie you to

Two points that are frequently reported wrongly, in opposite directions.

The regulation does name GTIN in its annex on passport content, so anyone who says the rules are scheme-neutral has not read the text.

It also foresees operators creating their own identifiers where no issuing agency is involved. So a company outside the GS1 system is not blocked, and a scheme conformant with the relevant ISO/IEC standards can be used instead.

The practical reading: if you are already inside a scheme, use it. GS1's own provisional DPP application standard says that within the GS1 system the product identifier shall be the GTIN and the operator and facility identifiers shall be the GLN. If you are outside it, a conformant alternative works, and the delegated act for your category is what settles the question for your products.

Where identifiers come from

Identifiers built to ISO/IEC 15459 have a defined structure: an issuing agency code, a company identification number allocated by that agency, and a serial unique within that company's domain. The registration authority for the scheme is AIM Global, and the register of issuing agencies is a public lookup.

Two practical consequences.

Store the identifier whole. Once assembled, the identifier is a single opaque value. Splitting it across database fields and reassembling it is how values get corrupted; the Odette specification is explicit that it should not be separated for data exchange purposes.

Do not assume a closed list of agencies. The register changes. A system with a hardcoded set of schemes will reject a customer's valid identifier eventually.

The question to ask a vendor

Can you carry the identifiers we already have, unchanged?

That is the test. A provider that stores your existing identifiers needs no licence from anyone, because storing someone else's identifier is not issuing one. A provider that requires you to adopt its own scheme is making a decision on your behalf about a registry you may already be in, and it makes leaving expensive: if migration means new identifiers, every carrier already printed on a physical product becomes wrong.

Junction stores customer identifiers and does not issue them. A customer that already holds a GTIN, a GLN, a DUNS number or a CAGE code hands it over and we carry it through the passport unchanged.

Sources

• Regulation (EU) 2024/1781 (ESPR), Annex III on passport content and Article 12 on identifiers.
• European Commission, *Digital Product Passport: FAQ*, January 2026 update, question 20.
• ISO/IEC 15459 series; AIM Global as registration authority.
• GS1 provisional DPP application standard GSCN 23-103, 9 April 2025.