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Digital Product Passport requirements arrive with their own vocabulary, and much of it is defined precisely in law rather than left to interpretation. Economic operators preparing for compliance under the Ecodesign for Sustainable Products Regulation (ESPR, Regulation (EU) 2024/1781) will meet these terms repeatedly in delegated acts, technical standards, and registry documentation.
Getting the definitions right early avoids costly misreadings later, particularly once product-specific delegated acts start layering additional obligations on top of the horizontal framework. Unless stated otherwise, every article cited below is from the ESPR, Regulation (EU) 2024/1781. This guide works through the terms in three groups: the core passport concepts, the roles the regulation assigns to different actors in the value chain, and the data and access mechanics that sit underneath both.
Digital product passport: Under Article 2(28) of the ESPR, a digital product passport is a set of data specific to a product, containing the information specified in the applicable delegated act adopted under Article 4, accessible via electronic means through a data carrier. The passport is not a single EU-wide document with fixed fields. Its exact contents are set product group by product group, which means a battery passport under the separate EU Battery Regulation (2023/1542) and a textile passport under the ESPR will hold different data even though both follow the same horizontal design principles. Article 9(1) of the ESPR is explicit that products can only be placed on the market or put into service where a passport is available under the relevant delegated act, and that the data in it must be accurate, complete, and up to date throughout.
Data carrier: Article 2(29) of the ESPR defines a data carrier as a linear barcode, a two-dimensional symbol, or another automatic identification data capture medium that a device can read. This is the physical or printed element, a QR code on a garment label or a marking on a battery casing, that links a product to its passport. Annex III to the ESPR sets out which standards these carriers must comply with, and Article 10(1)(b) requires the carrier to be physically present on the product itself, its packaging, or accompanying documentation, as specified in the relevant delegated act. In practice, this decision (product, packaging, or document) is one of the more consequential design choices a manufacturer makes early in passport implementation, since it affects labelling, packaging design, and where responsibility for the carrier's durability sits.
Unique product identifier: Article 2(30) of the ESPR defines this as a unique string of characters that identifies a product and also enables a web link to its digital product passport. Article 10(1)(a) requires the passport to be connected through a data carrier to a persistent unique product identifier. This identifier is what turns a scan of the data carrier into an actual retrieval of passport data, and its persistence matters: Article 11(e) requires the passport to remain available for the period set in the relevant delegated act, including after an insolvency, liquidation, or cessation of activity by the economic operator that created it.
Unique operator identifier and unique facility identifier: A unique operator identifier, under Article 2(31) of the ESPR, identifies an actor involved in a product's value chain. A unique facility identifier, under Article 2(33), identifies a location or building involved in that value chain. Article 12 sets out how these identifiers are requested and issued when they do not already exist, placing the obligation on whichever economic operator creates or updates the passport to request them on behalf of the relevant actor, and to pass on the full identifier details once issued. Article 12(2) and 12(3) also require that operator to first confirm with the relevant actor that no identifier already exists before requesting a new one, which is a small but easily missed procedural step.
Digital product passport service provider: Article 2(32) of the ESPR defines this as an independent third party, authorised by the economic operator placing the product on the market, that processes passport data to make it available to actors with a legal right to access it. Article 10(4) requires the economic operator placing the product on the market to maintain a back-up copy of the passport through such a provider. The second subparagraph of Article 11 adds a data protection layer: a service provider storing or processing passport data may not sell, reuse, or process that data beyond what is necessary for storage or processing services, unless specifically agreed with the economic operator concerned.
Economic operator: Article 2(46) of the ESPR defines economic operator as a collective term covering the manufacturer, the authorised representative, the importer, the distributor, the dealer, and the fulfilment service provider. Each of these roles carries distinct obligations under Articles 27 to 33, so identifying which role, or roles, a company occupies in a given transaction is the first step in working out what a passport requires of it. A single company can hold more than one role simultaneously, and Article 34 sets out circumstances in which an importer or distributor is treated as a manufacturer for the Regulation: specifically, where they place a product on the market under their own name or trademark, or modify a product already on the market in a way that affects its compliance.
Manufacturer: Article 2(42) of the ESPR defines a manufacturer as any natural or legal person that manufactures a product, or has one designed or manufactured, and markets it under their own name or trademark. Article 27 places the heaviest set of obligations on this role: ensuring the product meets performance requirements, ensuring a passport is available with a back-up copy held by a service provider, carrying out the conformity assessment procedure, and keeping technical documentation for ten years unless a delegated act specifies otherwise.
Authorised representative: Article 2(43) of the ESPR defines this as any person established in the Union who holds a written mandate from the manufacturer to act on their behalf regarding specified obligations. Article 28 confirms that the core duties of creating the passport and drawing up technical documentation cannot be delegated to this role; the mandate instead typically covers keeping documentation available to market surveillance authorities and cooperating with them on non-compliance.
Importer: Article 2(44) of the ESPR defines an importer as any person established in the Union who places a product from a third country on the Union market. Article 29 requires the importer to verify, before placing a product on the market, that the manufacturer has carried out conformity assessment and that a passport with a back-up copy exists, and to withhold placing the product on the market if there is reason to believe it is non-compliant.
Distributor and dealer: Article 2(45) of the ESPR defines a distributor as any person in the supply chain, other than the manufacturer or importer, who makes a product available on the market. Article 2(55) defines a dealer more specifically as a distributor or other person who offers products for sale, hire, or hire purchase to end users, including through distance selling. Article 30 sets verification duties for distributors, while Article 31 requires dealers specifically to ensure the passport is easily accessible to customers and potential customers, including in distance selling, and to display any required labels visibly.
Fulfilment service provider and independent operator: A fulfilment service provider is referenced throughout Chapter VII of the ESPR, with the underlying definition drawn by cross-reference to Regulation (EU) 2019/1020 on market surveillance. Article 33 of the ESPR requires this role to ensure that warehousing, packaging, addressing, or dispatching does not compromise a product's compliance. An independent operator, defined in Article 2(47) of the ESPR, is a person independent of the manufacturer who is involved in refurbishment, repair, maintenance, or repurposing, a category that includes waste management operators, repairers, and publishers of technical information. Independent operators are named in Article 11(b) among the actors entitled to access passport data based on their specified access rights.
DPP registry: Distinct from the passport itself, the registry is the EU-level database established under Article 13 of the ESPR, storing unique identifiers and, for products entering free circulation, the relevant commodity code. Article 13(4) places the obligation to upload this data on the economic operator placing the product on the market. Article 13(5) confirms that the registration identifier issued on upload is not, by itself, proof of compliance. The passport holds the detailed product data; the registry holds the identifiers used to verify authenticity and support customs and market surveillance checks under Article 15.
Access rights: Article 11(b) of the ESPR lists the categories of actor entitled to free and easy access to passport data, including customers, manufacturers, importers, distributors, dealers, professional repairers, independent operators, refurbishers, remanufacturers, recyclers, market surveillance authorities, customs authorities, civil society organisations, and trade unions. What each category can actually see is set at product group level in the relevant delegated act, so access rights are not uniform across the framework, and a company assuming one product group's access model applies elsewhere risks under- or over-sharing data.
Digital instructions: Article 27(7) of the ESPR requires manufacturers to accompany a product with instructions in digital format, made accessible through the passport's data carrier, while safety-relevant instructions must still be provided in paper form in a concise format. Customers can request the full digital instructions in paper format free of charge for up to six months after purchase, and manufacturers must keep the digital version accessible online for at least ten years after the product is placed on the market.
Interoperability: Article 10(1)(d) of the ESPR requires all data in a passport to be based on open standards, developed in an interoperable format, and to be machine-readable, structured, searchable, and transferable through an open data exchange network without vendor lock-in. Article 11(a) extends this to full interoperability between different passports required under different delegated acts. This requirement is why passport implementation is treated as a data architecture decision rather than a labelling exercise: a system built around a closed or proprietary format will not meet the essential requirements regardless of how complete its content is.
The terms set out here are not interchangeable, and the ESPR uses each one with a specific legal meaning attached to specific obligations. Passport and registry are different systems with different upload duties; identifier and data carrier are different components with different technical standards; and the six economic operator roles carry different weights of responsibility even where a single company occupies more than one of them at once. For an economic operator working through compliance for the first time, the practical value of a shared vocabulary is that it prevents obligations from being missed simply because they were assumed to sit somewhere else, under a different label, or with a different actor in the chain. As product-specific delegated acts are adopted under Article 4, this baseline terminology stays constant even as the data fields, access rights, and timelines built on top of it vary by sector.
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