How it works
What is an economic operator identifier, and do you need one?
An operator identifier names the company, not the product. No adopted EU act tells a New Zealand exporter which one to hold.
An economic operator identifier is a number for the business behind a product. You probably do not need one today. No adopted European Union act yet tells you which number to hold, so wait before you buy one.
That matters because somebody may try to sell you one. A supplier can sell you an annual registration for a duty that no adopted act has created. You then pay every year for a number that nobody has asked you for.
A digital product passport identifies a product, and it must also name the businesses behind that product. Each of those businesses needs a number that a system in the European Union can read.
An operator identifier names a company, not a product
Three different numbers sit in the same passport.
A product identifier names the thing you sell. The Global Trade Item Number (GTIN) behind the barcode on a merino jumper is one. See product identifiers.
An operator identifier names a company. It can name the manufacturer, the importer, or another party in the chain.
A facility identifier names a place, such as a mill or a warehouse.
Keep the three apart. A number that identifies your jumper cannot identify your company, and a European customer will ask for each one separately.
The ecodesign regulation lists the identifier and names no scheme
The Ecodesign for Sustainable Products Regulation (ESPR) is Regulation (EU) 2024/1781. It entered into force on 18 July 2024. Annex III lists what a passport must carry once a rule covers your product group.
| What the passport must carry | Where it is written | Status |
|---|---|---|
| The unique operator identifier of the manufacturer, and identifiers of other actors in the chain | Annex III, first paragraph, points (g) and (h) | Waits for a delegated act |
| An identifier requested for an actor that has none | Article 12(2) | Waits for a delegated act |
| Unique facility identifiers for the relevant locations | Annex III, first paragraph, point (i), with Article 12(3) | Waits for a delegated act |
| The name, the contact details and the unique operator identifier of the responsible operator established in the Union | Annex III, first paragraph, point (k) | Waits for a delegated act |
Read the status column before you act on any row. Each duty starts for a product group only when the European Commission adopts a rule for that group, called a delegated act. The Commission had adopted no such act for any group on 14 August 2026.
Now read what the regulation does not say. A search of the full text returns zero hits for GS1, for Digital Link, for IEC 61406 and for the Digital Object Identifier. That search covered the recitals, the 79 articles and every annex.
What ESPR does name is the ISO/IEC 15459 series, for the data carrier and the unique identifiers. The named parts are 1 to 6. Article 10(1)(c) makes that an interim rule, and it holds until the references of harmonised standards are published.
So no article of ESPR names a company number that you must buy.
The sources name two schemes, and the full list is behind a paywall
Two schemes appear in the material this site has read.
| Scheme | The standard or the body behind it | What the sources say |
|---|---|---|
| Legal Entity Identifier (LEI) | ISO 17442 | Commentary on EN 18219 treats it as the primary operator scheme. It is a paid annual registration. |
| Global Location Number (GLN) | GS1 | The same commentary says a GLN is also accepted. A GLN can name a company or one of its sites. |
An earlier draft on this site said that an exporter who needs an operator identifier must hold one of those two. That statement was wrong, and this page corrects it.
The sources name two schemes. They do not say that those two are the complete set.
EN 18219:2026 is the European standard for unique identifiers. The Commission cited it in Implementing Decision (EU) 2026/1736, which is in force. Its text is paywalled, and nobody on this site has read it. So this site publishes no count of the operator schemes it permits, and no claim about which schemes it names.
Commentary does give a count. Nobody has checked that count against the standard, so this site leaves it out. See EN 18219 and identifier schemes: what is verified.
Citation of a standard does not create a duty either. It gives a product built to that standard a presumption of conformity, and the standard stays voluntary.
Your importer's identifier matters before yours does
The operator that places the product on the European Union market carries the passport duty. A New Zealand manufacturer with no office in the Union does not place the product on that market. The European importer does.
An EU-funded consortium paper says a manufacturer outside the Union stays responsible for the passport. That paper is not law. Your customer will still ask you for the data.
So a passport usually needs the importer's operator identifier first. Annex III point (k) requires the identifier of the responsible operator established in the Union. Your company does not hold that position, and cannot fill that field.
Ask your importer for its operator identifier, and ask which scheme it uses. Write the answer into the supply contract before the first shipment. See who is the economic operator and importer obligations.
If you hold no identifier, the passport creator must request one for you
Article 12(2) of ESPR covers the case where an actor in the chain has no operator identifier. The operator that creates the passport must then request one on behalf of that actor.
That rule matters to you. Your company can appear inside a customer's passport without holding any number of its own today. The customer carries the job of getting one.
Two points follow for the contract. Agree who applies for the identifier. Agree who pays the fee. See agreeing data duties with your EU importer.
No source in this site's knowledge base names the New Zealand Business Number (NZBN) as a permitted operator identifier scheme for a passport. See why an NZBN is not enough.
The trade agreement gives you a route to ask for a number
The free trade agreement between New Zealand and the European Union is in force. Chapter 9 covers technical barriers to trade, and it has a clause on identification numbers.
Where a party requires a unique identification number from economic operators, it must issue such a number to operators of the other party. The agreement adds two conditions: without undue delay, and on a non-discriminatory basis.
This site gives that clause as a reading. No delegated act requires the number yet, so nobody has tested it. See the NZ-EU free trade agreement.
The battery passport duty starts on 18 February 2027, under another law
The identifier rules above come from ESPR. One passport duty already has a fixed date, and it comes from a different law. That law is the battery regulation, Regulation (EU) 2023/1542.
The duty starts on 18 February 2027. It covers three categories of battery:
- 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
A light means of transport battery carries no size threshold. See batteries.
Do not carry the ESPR operator identifier rules across to that duty, which sits in a separate instrument.
Buy no identifier yet, and ask your customer which scheme it uses
- Do not buy an identifier to meet a duty that has no adopted act.
- Ask your European customer which operator identifier scheme it uses.
- Ask who applies for an identifier if your company needs one.
- Record the name of the company that places your product on the market.
- Ask any supplier who cites a legal requirement to name the article.
- Check your sector date first. Read how to read the timeline.