#24 in the LEI Lightbulb Blog Series - Digital Product Passports: Why the LEI is the ideal choice for economic actor identification

A European standard, the new EU DPP Registry and the UN/CEFACT vocabulary now reference the LEI, making it a great fit for identifying the economic actors behind product data

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Digital Product Passports (DPPs) are emerging as an important tool to connect information across global value chains. By creating a structured digital record associated with a product, DPPs can make information about its origin, composition, sustainability characteristics, repairability, and recyclability more accessible throughout its lifecycle.

DPP initiatives are developing in several places at once. The EU is implementing them under its Ecodesign for Sustainable Products Regulation (ESPR), and the UK closed a call for evidence on digital product records on 21 September 2026. At the UN, Recommendation No. 49 of the United Nations Centre for Trade Facilitation and Electronic Business (UN/CEFACT) sets the policy framework for transparency and traceability across value chains, and the UN Transparency Protocol (UNTP) provides the technical framework, including a specification for DPPs.

Every DPP depends on a reliable link between product data and the organizations responsible for it.

Previous editions in the LEI Lightbulb Blog Series have tracked recognition of the LEI in financial regulation, from the EU's Markets in Crypto-Assets (MiCA) regulation and the final joint rule under the U.S. Financial Data Transparency Act (FDTA) to the Financial Action Task Force's (FATF) draft guidance on implementing Recommendation 16. This edition looks at a different field: the standards and infrastructure taking shape for Digital Product Passports.

Why organizational identity matters in a DPP

The Organisation for Economic Co-operation and Development (OECD) estimates that around 70% of international trade involves global value chains. For DPPs, this matters because much of the required information must be captured 'upstream' as the product is being manufactured. For example, a machine component may pass through a multijurisdictional chain of suppliers and processors before becoming a finished product, which makes that data harder to capture. Tracing the journey from one entity to the next is harder than it looks.

Following a product's manufacturing journey from one entity to the next is often much more complex than it may seem at first. Across borders, the same legal entity may appear under different names in different systems, and national identifiers vary between jurisdictions. In the EU, the ESPR anticipates this. It defines a unique operator identifier as one that identifies “an actor involved in a product’s value chain”, which covers more than the economic operators that bring products to the EU market. Where a DPP must include such an identifier and another actor in the value chain does not yet have one, the operator creating the DPP must request one on that actor’s behalf.

How the LEI complements product and facility identifiers

No single identifier needs to do everything. EN 18219:2026, the European standard on unique identifiers for DPPs, distinguishes between three types: product identifiers, which can work at the level of a model, a batch, or an individual item; facility identifiers, for the locations and buildings involved in a product’s value chain; and economic operator identifiers.

The Legal Entity Identifier (LEI) belongs in the third category. For economic operators, EN 18219 includes an approach based on ISO/IEC 6523, an international standard for identifying organizations, and lists the LEI (ISO 17442) among its examples of identifier schemes. The LEI complements product and facility identifiers by adding an organizational identity layer, with verified reference data anyone can access free of charge through the Global LEI Index.

The UN's work points the same way. The UN/CEFACT vocabulary includes a dedicated property for the LEI, leiCode, and UNTP’s DPP specification asks each passport to identify its issuer, manufacturer, and facility operator, with a resolvable, verifiable identifier.

From standards to the DPP Registry in the EU

To make DPPs work consistently across products and sectors, the European Commission asked the European standardization organizations CEN, CENELEC, and ETSI to develop harmonized standards on areas including identifiers, data carriers, interoperability, and data exchange. With six of these cited in the Official Journal of the European Union in July 2026, DPPs that conform are presumed to meet the ESPR requirements those standards cover. In the same month, the Commission launched the DPP Registry, where economic operators register DPPs before placing products on the EU market.

The Registry’s User Guide for Economic Operators lists the LEI among the identifiers a legal person can provide when enrolling an organization, alongside its national trade registry, VAT, and electronic ID numbers.

The LEI is not mandatory for EU DPPs. The ESPR leaves it to product-specific rules to decide whether unique operator identifiers are required, and most of those rules are still to come. We do know that battery passports become mandatory for certain batteries from 18 February 2027 under the separate Batteries Regulation, and under the ESPR, a delegated act for iron and steel products is tentatively scheduled for the fourth quarter of 2026.

Forthcoming initiatives such as the European Product Act could extend DPPs beyond the ESPR. In October 2025, the European Parliament called for a horizontal DPP covering all products sold in the EU and connected to market surveillance systems such as the EU Safety Gate. If those obligations include economic operator identifiers such as the LEI, authorities could more reliably identify the organizations responsible for a product when it proves unsafe or non-compliant.

Verifying who acts for an organization

Identifying the organization is just the first step. Accurate DPP data capture must also involve people acting on an organization’s behalf, adding or updating data and accessing restricted information. The Registry’s implementing rules, in force since 6 August 2026, already reflect this: only verified economic operators can register DPPs, and each verified operator manages access for the users acting on its behalf. At the UN, UNTP’s Digital Identity Anchor links an organization’s registered identity to the decentralized identifier it uses to sign credentials such as DPPs.

The verifiable LEI (vLEI) is built for precisely this kind of verification. It extends verified organizational identity into the digital domain, enabling counterparties to computationally verify a person's identity, role, and delegated authority when acting on behalf of a legal entity. Together, the LEI identifies the organization and the vLEI enables its authorized representatives to be computationally verified.

What comes next

DPP frameworks are still being shaped, and each should cover how organizations are identified, alongside products and facilities. Because the LEI is a global ISO standard already referenced in European implementation and part of the UN/CEFACT vocabulary, it is a strong candidate for identifying the organizations behind product data in DPPs worldwide. At GLEIF, we are actively contributing to these discussions. UN/CEFACT’s public review of its Digital Product Passport Overview and Fundamental Principles project is open until 12 October 2026. We encourage all organizations working on DPPs to participate.

The 'LEI Lightbulb Blog Series' from GLEIF aims to shine a light on the breadth of acceptance and advocacy for the LEI across the public and private sectors, geographies, and use cases by highlighting which industry leaders, authorities, and organizations are supportive of the LEI and for what purpose.

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