Digital Product Passport LEI: Is It Required?

A digital product passport LEI is an accepted way to identify an organisation in the EU DPP Registry, but an LEI is not mandatory for EU digital product passports. The registry also accepts other identifiers, and a legal person must verify its identity with a qualified electronic seal (QSeal). For specified batteries, passport requirements will apply from 18 February 2027.

Key points: is an LEI required for a digital product passport?

• The LEI is an accepted DPP Registry identifier, not a required one. The Commission marks the national trade register identifier as preferred.
• The identifier entered when enrolling a legal person must fully match the corresponding attribute in its QSeal certificate. An LEI does not replace the QSeal or registry verification.
• The registry’s operator-verification rules are in force. The battery-passport requirement for specified batteries will apply from 18 February 2027.
• Whether a unique operator identifier is required for a product depends on product-specific rules. Do not treat a possible future rule as an obligation already in place.

What a digital product passport is, and when it applies

Regulation (EU) 2024/1781 (Ecodesign for Sustainable Products Regulation, ESPR) provides the framework for digital product passports (DPPs) and for a Commission DPP registry under Article 13. Its approach to identifying operators should not be read as a blanket instruction for every company to obtain an LEI. According to GLEIF blog #24 – Digital Product Passports and the LEI (8 October 2026), product-specific rules determine whether a unique operator identifier is required, and most such rules are still to come.

A date is already set for battery passports. Under Regulation (EU) 2023/1542 (Batteries Regulation), Article 77(1), each LMT battery, each industrial battery with a capacity greater than 2 kWh, and each electric vehicle battery placed on the market or put into service must have an electronic record, called a battery passport, from 18 February 2027. The regulation is in force, but that passport requirement has a future start date.

Do not apply the battery date to other product groups. GLEIF describes an act for iron and steel products as tentatively scheduled for Q4 2026; that tentative schedule is not an adopted product requirement. The practical question for any operator is which product-specific rule covers its products, rather than whether every DPP will demand the same identifier.

What is a unique operator identifier?

The ESPR defines a unique operator identifier as “a unique string of characters for the identification of an actor involved in a product’s value chain.” Its recital says that, where appropriate, a DPP should be linked to a unique operator identifier and a unique facility identifier issued in accordance with internationally recognised standards. An operator identifier and a facility identifier therefore describe different things; the regulation does not make an LEI the sole means of identifying an operator.

For a company assessing its DPP data, the distinction matters. Identifying the legal person enrolling in the registry is an immediate verification task; deciding what identifiers a product passport must carry depends on the applicable product rule. Keep those questions separate when reviewing existing records and preparing information for the registry.

DPP Registry verification, QSeal and accepted identifiers

The European Commission – The DPP Registry says economic operators register DPPs before placing products on the EU market. Commission Implementing Regulation (EU) 2026/1778 (DPP registry) has been in force since 6 August 2026. Only verified economic operators can register DPPs. A legal person proves its identity with a QSeal from a qualified trust service provider; verified status lasts at most 3 years or until the electronic identification means expire, whichever is earlier.

When enrolling an organisation, the European Commission – DPP Registry User Guide for Economic Operators lists these choices. The identifier supplied must fully match the corresponding attribute in the QSeal certificate.

Identifier type in the user guide	What to check
NTR – National Trade Register	Marked preferred; check the corresponding QSeal attribute.
LEI (ISO 17442)	Accepted option; check the corresponding QSeal attribute.
VAT number	Accepted option; check the corresponding QSeal attribute.
eID	Accepted option; check the corresponding QSeal attribute.
Local definition with a country prefix	Accepted option; check the corresponding QSeal attribute.

The table describes enrollment choices, not a ranking of identifier schemes beyond the guide’s preferred NTR marking. Having an LEI does not by itself make an organisation a verified operator. Before choosing an identifier, compare the value the organisation intends to enter with the attribute in its QSeal certificate.

Where the LEI fits under EN 18219 – and its limits

GLEIF explains that EN 18219:2026, the European standard on unique identifiers for DPPs, distinguishes product, facility and economic operator identifiers. For economic operators, it includes an approach based on ISO/IEC 6523 and lists the LEI (ISO 17442) among its example identifier schemes. That gives an ESPR economic operator a reason to consider an LEI, but an example in a standard is not a general legal requirement to use one.

GLEIF explicitly states that the LEI is not mandatory for EU DPPs. The Commission’s registry guide likewise lists it alongside other accepted identifiers and marks NTR as preferred. An organisation choosing an LEI should therefore make that choice against its QSeal details and the relevant product rule, not on the assumption that the LEI replaces either.

If an organisation already has an LEI, it can consult the guide to look up and check its LEI record before reviewing the registry identifier choice. For a different compliance context, the LEI in AML customer identification is discussed separately; that context does not change the DPP Registry’s identifier options.

Preparation checklist for economic operators

1. Identify the applicable product rule. If the organisation handles a battery category named in Article 77(1), plan around 18 February 2027. For other products, check the relevant product-specific requirements rather than assuming the battery date applies.
2. Decide who will enroll. Establish which legal person will act as the economic operator in the registry. Check the Commission’s registry instructions before preparing its enrollment details.
3. Review the QSeal information. For a legal person, the QSeal is part of identity verification. Compare its corresponding attribute with the identifier the organisation plans to provide; a mismatch needs attention before enrollment.
4. Choose an accepted identifier. Review the guide’s preferred NTR option and the other listed choices, including the LEI. If an LEI is appropriate and the organisation needs one, it can apply for an LEI. Do not obtain one solely on the mistaken premise that every DPP requires it.
5. Review an existing LEI if using it. Check its record and whether the identifier matches the relevant QSeal attribute. Where an existing LEI needs renewal so its data stays current, renew the LEI as part of that review.
6. Confirm the remaining requirements. Check the applicable product rule and registry guidance before registration. Where the organisation’s obligations depend on its particular products or role, confirm the position with its regulator or adviser.

Start by checking the product category and the organisation’s QSeal attribute; those determine which passport deadline and identifier choice need attention next.