I should have been more clear ... the Express Service Code cannot be pulled from a WMI query. If you pull the whole WMI BIOS string (wmic bios), the ESC is not in there at all. I don't think there is any way to pull that information out, as even the BIOS update packages check the version through WMI.
All Dell computers have a Service Tag and a corresponding Express Service Code. In fact, nearly all computers have a Serial Number stored in the BIOS and the wmic bios get serialnumber will return that regardless of make.
As for why it is not returning a Service Tag for all of them ... Is the query returning a blank result? or is the query not running or giving an error? Will it return the ST if run locally? or is it just not returning anything when run remotely? I have noticed that it sometimes will not run remotely in a workgroup, and it will not return anything if the motherboard was replaced and the ST not set in the BIOS on the replacement, and I believe WMI can be shutoff or given restricted permissions. What OS version/SP do you have installed on them? x86/x64? If different, is there a pattern?