pub struct ResponsibleOperator {
pub did: String,
pub name: String,
pub role: OperatorRole,
pub eu_operator_id: Option<String>,
pub eu_operator_id_scheme: Option<String>,
pub country: String,
pub registered_trade_name: Option<String>,
pub postal_address: Option<String>,
pub electronic_address: Option<String>,
}Expand description
Identifies an economic operator responsible for a DPP.
Under ESPR, the “responsible economic operator” is whoever places or makes the product available on the EU market. This can be the original manufacturer, an importer, a distributor, or a remanufacturer.
§Contact details
postal_address,
electronic_address and
registered_trade_name exist because four
separate provisions require the same four-part shape of whoever is
answerable for a product, and confirmed against the verbatim OJ text they
are: ESPR Art. 27(6) (manufacturer) and Art. 29(3) (importer) —
“name, registered trade name or registered trade mark, postal address at
which, and electronic means of communication through which, they can be
contacted”; Art. 4(4) of Regulation (EU) 2019/1020 — “the name,
registered trade name or registered trade mark, and contact details,
including the postal address”; and Art. 16(3) of Regulation (EU)
2023/988 — the same, “including the postal and electronic address”.
ESPR Annex III, point (k) is what puts them in the passport: “the name, contact details and unique operator identifier of the economic operator established in the Union responsible for carrying out the tasks set out in Article 4 of Regulation (EU) 2019/1020 or Article 15 of Regulation (EU) 2023/988, or similar tasks pursuant to other Union law applicable to the product”. Contact details are never a free string in any of the four.
⚠️ That quote’s “Article 15” is the Regulation’s own cross-reference, and
it points at the wrong article — Art. 15 of 2023/988 is Cooperation of
economic operators with market surveillance authorities; the
responsible-person provision is Art. 16. The quote is left exactly as
enacted, and
ResponsibilityBasis::GeneralProductSafety
carries the explanation, including why it changes nothing in substance.
All three are Option because this type is a persisted shape — it is stored
inside the transfer chain — and the envelope rule is additive-only. None
means not stated, never “has none”.
Fields§
§did: StringThe operator’s DID (e.g. did:web:acme.example.com).
name: StringHuman-readable name of the economic operator.
role: OperatorRoleThe operator’s role in the supply chain.
eu_operator_id: Option<String>EU-assigned economic operator identifier, if available.
eu_operator_id_scheme: Option<String>The scheme Self::eu_operator_id is expressed in — "vat", "lei",
"eori", "duns". None when no EU identifier is held.
Paired with the value because an identifier without its scheme cannot be stated truthfully to a registry: the value alone does not say what it is, and guessing produces a false claim rather than a missing one.
country: StringISO 3166-1 alpha-2 country code of the operator’s establishment.
registered_trade_name: Option<String>Registered trade name or registered trade mark, where it differs from
name.
All four provisions name it as an alternative to the legal name — “name,
registered trade name or registered trade mark” — because the two are
frequently different and a reader holding the product sees the trading
one. Kept as a separate field rather than overloading name, which is
the legal name.
postal_address: Option<String>Postal address at which the operator can be contacted.
ESPR Art. 27(6) adds a constraint the other three do not: “The address shall indicate a single point where the manufacturer can be contacted.” That is a property of the content, not of the shape, so nothing here enforces it — a free string cannot express “single point”, and a structured address still could not say whether it is the only one.
electronic_address: Option<String>Electronic means of communication through which the operator can be contacted — an email address, or a contact URL.
Distinct from did, and deliberately: a DID document
resolves keys. Nothing in it is required to be a mailbox or a form, so it
is not a channel through which a person can be contacted, and reading it
as one would satisfy the obligation on paper and not in fact.