How it works
What a facility identifier is, and whether you need one
A facility identifier names a place, not a company and not a product. No law requires one from a New Zealand exporter today.
A facility identifier is a number that names one place, such as a factory, a tannery or a packing shed. Nothing requires one from you today: the European Commission had adopted no ecodesign delegated act for any product group on 14 August 2026.
A facility identifier does not name your company, and it does not name your product. If you buy a numbering service now, you spend money that no law requires. A European buyer can still ask which of your sites made a batch. Your answer must come from a record that names the site for each batch.
This page is also a correction. An earlier draft of this site said that EN 18219 uses the Global Location Number as the facility identifier scheme. No source in this site's knowledge base supports that claim, and this site withdraws it.
A digital product passport names three different things
A digital product passport uses more than one type of identifier. Each one answers a different question.
| Identifier | Question it answers | Example |
|---|---|---|
| Product identifier | Which product is this? | The number behind the barcode on a merino jumper |
| Operator identifier | Which company is responsible? | A number for the manufacturer or for the importer |
| Facility identifier | Which place made or processed it? | A number for the mill that knitted the jumper |
See product identifiers and operator identifiers for the first two. This page covers the third.
A company number cannot name the site that made a batch. One company can run more than one site. One contract processor can work for more than one company. So the question "which place" needs its own number.
A New Zealand Business Number (NZBN) names a company. It cannot say which site made the batch. See why an NZBN is not enough.
This site cannot cite an ecodesign article that requires a facility identifier
The Ecodesign for Sustainable Products Regulation (ESPR) is Regulation (EU) 2024/1781. Annex III lists what a digital product passport holds.
| Item | Detail |
|---|---|
| The law | Regulation (EU) 2024/1781, the Ecodesign for Sustainable Products Regulation (ESPR) |
| Status | In force since 18 July 2024 |
| The unique operator identifier of the manufacturer | Annex III, points (g) and (h) |
| The data carrier and the unique product identifier | Annex III, second paragraph, the ISO/IEC 15459 series |
This site can name the annex points for the two identifier rows above. It cannot name an annex point or an article that requires a facility identifier.
Ask a supplier who tells you the ecodesign regulation requires a facility identifier to name the article. Then read that article. See what a component supplier faces for the customer request that can still reach you.
The regulation names no identifier scheme
A search of the full regulation returns no hit for GS1, for Digital Link, for IEC 61406 or for the digital object identifier (DOI). The search covered the recitals, the 79 articles and every annex.
What the ESPR names is the ISO/IEC 15459 series. It names parts 1 to 6, for the data carrier and the unique product identifier. Article 10(1)(c) makes that an interim rule. It runs until the references of harmonised standards are published.
So no article tells you to use one company's numbering system for your factory.
Correction: no source says EN 18219 names the Global Location Number
Warning: do not buy a numbering service because a supplier says a standard demands one for your factory. Ask that supplier to name the standard and the clause.
An earlier draft of this site said that EN 18219 uses the Global Location Number (GLN) as the facility identifier scheme. That claim is withdrawn. No source in this site's knowledge base supports it.
The Global Location Number is a GS1 number. The published material about EN 18219 describes product identifier schemes and operator identifier schemes. It does not describe a facility identifier scheme.
Some companies use a Global Location Number for a site because they already hold GS1 numbers. That is an implementation choice, and it may be a sensible one. It is not a requirement of any standard that this site can verify.
EN 18219 is paywalled, so this site publishes no list of facility identifier schemes
EN 18219:2026 is the cited European standard for unique identifiers. Nobody here has read it, because the text sits behind a paywall. One standard in the set costs between 190 and 370 euros on the distributor listings. See why the standard texts are paywalled.
So this site publishes none of these:
- a count of the identifier schemes that EN 18219 permits
- a list of the facility identifier schemes that EN 18219 permits
- a statement that one scheme is the primary one for a site
Identifier schemes: what is verified states what is checked and what is not. EN 18219 covers the standard itself.
Nothing requires a facility identifier from you today
The European Commission had adopted no ESPR delegated act for any product group on 14 August 2026. A passport duty starts with a delegated act for each group. Until one exists for your product, Annex III asks nothing of you. See what a delegated act is.
One passport duty is real, and it comes from a different law. The battery regulation is Regulation (EU) 2023/1542. From 18 February 2027 three categories of battery must have a passport:
- each light means of transport (LMT) battery, such as an e-bike battery
- each industrial battery with a capacity greater than 2 kilowatt hours
- each electric vehicle battery
This site does not state if a battery passport must carry a facility identifier. That point is not verified here. See batteries.
Build the site record before you buy a number
A number is easy to add later, but the record behind it is not.
If a facility identifier becomes a requirement for your product group, the task will not be the format of the number. The task will be to say which of your sites, and which of your contract processors, touched each batch.
Build that record now:
- List each site you own that makes, processes or packs the product.
- List each contract processor that touches it, such as a dyehouse or a bottler.
- Record which site handled which batch, and on which dates.
- Name one person in your company to keep that record current.
A merino jumper can pass through more than one site before it ships. If a buyer asks which site scoured the wool, the answer must not depend on one person's memory.
That record stays useful whatever scheme a future rule names.
Four questions for your European customer
- Which of my sites do you need named in the passport?
- Which identifier scheme do you use for a site?
- Who requests an identifier when a site has none?
- Who updates the record after the first shipment?
Put the answers in writing before you agree to supply the data. See agreeing data duties with your importer.
Find out where your product data is, and who owns it. See what this means for New Zealand exporters and how a passport works.