Factory, Manufacturing Location and Country of Origin in Digital Product Passports
Does a DPP require factory or country-of-origin data? Separate manufacturer, plant, facility ID, country of manufacture, origin, provenance and supplier location by regime.
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- Overview
- The terms are not interchangeable
- Does every DPP require factory information?
- Does every DPP require country of origin?
- Manufacturer versus manufacturing facility
- Is country of manufacture the same as country of origin?
- Batteries: manufacturing-plant location is adopted passport
- Textiles: production-site concepts are in official developme
- Toys: factory addresses belong in technical documentation, n
- Detergents: operator address is not a factory field
- Food, cosmetics and other adjacent regimes
- Are facility identifiers mandatory?
- Factory data also has a granularity problem
- Collection is not the same as publication
- A practical field model
- What product-data fields should companies distinguish now?
- Direct answers
- Primary sources
A Digital Product Passport does not universally require factory information or country of origin. More importantly, several concepts that are often grouped under “where was it made?” are legally and operationally different:
- manufacturer legal entity
- manufacturer or operator address
- manufacturing facility
- factory or plant location
- facility identifier
- country of manufacture
- country of origin
- provenance
- supplier location
- upstream supply-chain information.
A reliable DPP data model keeps them separate. For the broad category landscape, see Digital Product Passport Requirements by Product Category.
The terms are not interchangeable
| Concept | What it describes | Do not confuse it with |
|---|---|---|
| Manufacturer | The legal/economic actor that has the manufacturer role under the relevant product law. | Brand name or factory. |
| Operator address | Legal/contact address of the responsible actor. | Place where the product was physically made. |
| Manufacturing facility / factory / plant | Physical production site. | Country of origin or operator address. |
| Facility identifier | Identifier assigned to a site/facility. | The product UPI or operator identifier. |
| Country of manufacture | Country where a defined manufacturing activity took place. | Legal customs origin in every case. |
| Country of origin | A legal origin concept determined under the applicable origin rules. | Factory location or supplier country. |
| Provenance | Broader source/origin context whose legal meaning depends on the regime. | One universal DPP field. |
| Supplier location | Location of a supplier in the upstream chain. | Factory that made the final product. |
| Supply-chain information | Potentially multiple upstream actors, sites and relationships. | A single origin country. |
Does every DPP require factory information?
No.
The horizontal DPP architecture does not create a universal mandatory factory field for every passport.1
Product-specific legislation decides whether a production location belongs in the passport.
The current cross-category evidence gives three particularly useful examples:
- Batteries: manufacturing-plant location is part of the adopted Battery Passport information architecture.2
- Textiles: production-site and processing-location concepts appear in official preparatory work, but final textile DPP law is not adopted.3
- Toys: manufacture and storage addresses are required in technical documentation, but they are not simply mandatory DPP fields in Annex VI.4
Those three positions should never be flattened into one yes/no rule.
Does every DPP require country of origin?
No universal DPP country-of-origin requirement is established.
Country of origin can already be legally required in some sectors or customs/product contexts. That does not automatically make it DPP content.
The correct sequence is:
- determine whether origin is already legally required under another regime
- determine what the applicable DPP law says
- keep any adjacent-law origin fact labelled as adjacent law unless the DPP instrument selects it.
This matters particularly for textiles, where “country of origin” is frequently presented online as if it were already a settled universal textile DPP field. Current primary evidence does not support that certainty.
Manufacturer versus manufacturing facility
A manufacturer is a legal actor.
A manufacturing facility is a physical location or site.
One manufacturer can operate multiple factories. One factory can potentially manufacture goods for multiple legal entities or brands. The manufacturer's registered address can be in a different country from the plant.
A product-data model that stores all three in a single manufacturer text field will struggle to answer future regulatory questions accurately.
At minimum, separate:
- legal entity name
- legal role
- legal/contact address
- facility name
- facility address / geographic location
- facility identifier, if used
- relationship between product/batch and facility.
Is country of manufacture the same as country of origin?
Not necessarily.
“Made in” language and customs origin depend on legal rules about how origin is determined, including the nature of production and, in some contexts, substantial transformation.
A company may know the final assembly factory without having enough information to determine a legally correct country of origin for every purpose.
That is why a DPP should not derive country_of_origin = factory.country as a default rule.
Origin should be a separately governed fact with its own legal/evidential basis.
Batteries: manufacturing-plant location is adopted passport information
The Battery Regulation is the clearest current adopted DPP example for factory information.
Annex XIII includes the geographical location of the battery manufacturing plant in the passport information architecture.2
This is a plant/location fact.
It should not be casually rewritten as:
- country of origin
- manufacturer registered address
- full battery supply chain
- a universal facility-ID requirement.
Battery law also contains separate product, manufacturer, composition, sourcing and lifecycle information. Those fields may interact, but they remain distinct concepts.
Textiles: production-site concepts are in official development, not final law
The Commission currently plans the textile ESPR delegated act for Q4 2027.5
The May 2026 JRC supporting study explores candidate information including production sites and processing locations.3
That is a strong signal that facility/location data may matter in the future textile DPP design.
It is not a final legal requirement.
The safe wording is:
Official textile preparatory work considers production-site and processing-location information. The final textile delegated act will determine whether, how and at what access level those data become DPP requirements.
A business can map its factories now without publicly labelling that exercise “mandatory textile DPP compliance”.
Toys: factory addresses belong in technical documentation, not automatically the DPP
The Toy Safety Regulation provides a useful control against over-reading product law.4
Annex V, on technical documentation, requires addresses of places of manufacture and storage.
Annex VI Part I, on mandatory Toy DPP information, does not simply reproduce those factory/storage-address fields.
A manufacturer address belongs in the mandatory DPP data. The separate physical places of manufacture and storage sit in technical documentation.
Therefore:
Factory information can be legally required for compliance without being mandatory DPP content.
This distinction is central to the whole Observatory.
Detergents: operator address is not a factory field
The adopted detergent DPP includes manufacturer/operator identity and address information.6
The Annex VI mandatory dataset does not establish a universal manufacturing-factory location field comparable to the Battery Passport plant location.
This is another reason not to treat “manufacturer address” as a synonym for “factory”.
Food, cosmetics and other adjacent regimes
Food
Food is outside ESPR.1
Existing food law can require country-of-origin or place-of-provenance information in defined circumstances.7 That is Required under other law, not evidence of a generic food DPP.
Cosmetics
No generic EU cosmetics DPP is established by current evidence. Cosmetics law contains structured product information and, for imported cosmetics, defined origin-related information.8
Again, adjacent sector law is useful data. It is not a DPP field merely because it is structured.
Jewellery & watches
No generic EU jewellery/watches DPP is established by current evidence. General product-safety, REACH and defined conflict-minerals obligations may create identity or upstream information in particular scopes. None creates one universal factory/origin DPP field for all jewellery.910
Are facility identifiers mandatory?
Not universally.
A unique facility identifier is a separate identity object that a product-specific act can require or make useful. Current horizontal EU DPP evidence does not establish that every DPP needs one.1
If your business already has stable facility IDs, preserve them. They are useful for:
- connecting products or batches to production sites
- handling site name/address changes
- integrating supplier and manufacturing systems
- avoiding free-text factory duplication.
But do not present the existence of an internal facility ID as proof of a universal DPP legal requirement.
Factory data also has a granularity problem
Even where facility information matters, a business still needs to know what the site relationship applies to.
A model may be produced in several factories. A single batch may come from one site. Different production stages may occur in different countries. Final assembly may happen somewhere different from dyeing, finishing, component manufacture or cell production.
A single free-text field such as factory = China cannot represent those relationships reliably.
A more durable structure separates:
- facility identity
- process or production stage
- product/model relationship
- batch/lot relationship where relevant
- effective dates
- evidence supporting the relationship.
This does not predict what a future delegated act will demand. It avoids losing the distinctions needed to answer it.
See Digital Product Passport Granularity: Model, Batch or Item? for the separate passport-level question.
Collection is not the same as publication
A company may have good reasons to collect facility and supplier information before the law requires that information in a public DPP.
Internal collection can support:
- quality management
- supplier assurance
- customs/origin analysis
- product-safety investigations
- due diligence
- future regulatory readiness.
Publication is a different decision.
The fact that a business knows a factory address does not mean the address should automatically be visible to every consumer. The applicable product law and access architecture determine what belongs in the DPP and who may see it.
This is particularly important for future textile requirements, where official preparatory work can justify internal readiness without establishing the final public-access treatment.
A practical field model
A cross-category product system can keep the concepts distinct using separate records such as:
| Object | Example fields | Evidence question |
|---|---|---|
| Legal operator | legal name, role, registered address, UOI | Which legal source or company record establishes the actor? |
| Facility | facility name, address, coordinates where justified, facility ID | Which source establishes that this site exists and is the correct site? |
| Production relationship | product/batch, facility, process, dates | What evidence shows this product or batch was made or processed there? |
| Origin assertion | country, origin rule/basis, scope, verification date | Which legal origin rule and evidence support the assertion? |
| Supplier relationship | supplier, supplied component/material, effective dates | Does this describe supplier identity, manufacturing location or both? |
Keeping these records separate makes later publication rules easier to apply and reduces the risk of turning a convenient internal shortcut into an incorrect legal statement.
What product-data fields should companies distinguish now?
PREPARE
Create separate governed objects for:
Legal actor
- manufacturer name
- manufacturer role
- registered/contact address
- operator identifier where applicable.
Facility
- facility name
- facility address
- country
- geographic location if needed
- internal or external facility identifier
- operator relationship.
Product-to-facility relationship
- product/model
- batch/lot if relevant
- process/stage
- valid-from / valid-to dates
- evidence source.
Origin / provenance
- asserted country of origin
- legal basis / rule used
- evidence
- date verified
- scope of the assertion.
WATCH
- textile delegated act and its production-site/access rules
- iron and steel delegated act
- aluminium and tyre measures
- any product-specific facility-identifier requirements.
DO NOT HARD-CODE
- factory country = country of origin
- manufacturer address = manufacturing plant
- supplier country = origin
- every DPP requires factory information
- every factory datum is public.
Direct answers
Does every DPP require factory information?
No. Battery law includes plant location; other categories differ or remain unresolved.
Does every DPP require country of origin?
No universal requirement is established.
Does the Battery Passport require plant location?
Yes. Battery manufacturing-plant geographic location is part of the adopted Battery Passport information architecture.
Is factory information required in textile DPPs?
Not yet as final law. Official preparatory work considers it, but the delegated act is still future.
Is factory information required in Toy DPPs?
Factory and storage addresses are required in Toy technical documentation, but they are not simply mandatory Toy DPP Annex VI fields.
Are facility identifiers mandatory?
Not universally.
Keep exploring
The questions this page usually raises next.
- CompareCategory requirementsIs factory information final for textiles?Natural deeper or practical continuation.
- CompareCategory requirementsWhere does manufacturing-plant information appear in Battery Passports?The cross-category reference should lead to a concrete example or practical next step.
- Related questionSpecific questionHow should textile teams separate site, origin and product hierarchy now?The cross-category reference should lead to a concrete example or practical next step.
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Primary sources
This resource explains regulatory distinctions around factory and origin information. It is not personalised legal advice.