How do I give each product a unique identification code?
A unique code per product, linked to the passport
Every product that falls under the digital product passport receives its own identification code that links it to the correct passport data. This code is not a standard internal article number: it is the key that allows a customs authority, another market participant or a consumer to find the passport of that exact product, batch or model. In addition to the identification code of the product itself, the regulation uses an identification code for the market participant responsible for the product, and an identification code for the physical facility where the product was made or processed. These three codes together ensure that a product, the party placing it on the market, and the place where it comes from, are traceable.
Who this applies to, and at what level
This obligation applies to products for which a product passport is made mandatory through a delegated act for the relevant product group. Whether the identification code is assigned per unit, per batch or per model is not determined in Article 12 itself, but is determined per product group in that delegated act. For a product that comes onto the market as an individual item, with for example its own serial number, a code per unit makes sense. For products that are identical in large series, a code per model or per batch may suffice. This means that the question 'must this be per unit or per model' is answered differently per product group, and the answer must therefore be sought in the regulations for that specific product group, not in Article 12 on its own.
No separate date; the moment follows from the product group
There is no standalone date on which the obligation for a unique identification code arises, separate from the moment when a product passport becomes mandatory for a product group. That obligation arises at the moment when a delegated act for that product group becomes applicable, with the implementation date specified in that act itself. Until that moment, no obligation exists for that product group to provide products with this code. For a specific product group, the delegated act for that group is therefore always the source to check when exactly this applies; this is not stated in Article 12 or Article 11 itself.
How this is handled in practice
The first step is to determine whether, and if so at what level — unit, batch or model — the identification code for the product group in question must be assigned, as soon as the delegated act for it is published. Next, each issued code must actually be unique: no two products, batches or models with the same code. Subsequently, the code is linked to the corresponding passport data, so that whoever looks up or scans the code arrives at the correct dataset. In addition, the identification code of the market participant and that of the facility are kept separately and consistently, so that the three codes together provide complete traceability. Finally, the identification code is processed into or linked to the data carrier — such as the QR code — that is placed on or with the product, so that the passport can be requested via that code; the requirements for that data carrier and the functioning of the passport are set out in Article 11.
Where this is established: Article 12 and Article 11 of the ESPR
This obligation follows from Article 12 of Regulation (EU) 2024/1781 (ESPR), which governs the unique identification code of the product, the market participant and the facility. Article 11 of the same regulation describes the technical design and functioning of the digital product passport, including the way in which the data carrier and the identification code together provide access to the passport data. For the exact level — unit, batch or model — and for the implementation date per product group, the delegated act for that product group is always the source to consult.
If you are already working with a product group for which a delegated act is being prepared, you can start mapping at what level products are currently distinguished — per unit, per batch or per model — and whether the existing internal numbering is suitable to serve as a basis once the identification code becomes mandatory. Once the delegated act for that product group is published, that act will provide clarity on the precise level and the implementation date.
Where this is based on
- Regulation (EU) 2024/1781 (ESPR), Article 12 (unique identifier code)
- Regulation (EU) 2024/1781 (ESPR), Article 11 (technical design and operation of the digital product passport)
The regulation itself is on EUR-Lex. We provide references for each claim; you do not have to take our word for it.
What you must do concretely
What is expected of you
Each product receives its own unique identification code
Article 12 of the ESPR (Regulation (EU) 2024/1781) requires that a product falling under the digital product passport be provided with a unique identification code. This code is the key by which the passport of that specific product (or that specific product series, depending on how the passport is set up) is found. For a company of 10 to 100 employees, this means in practice that a system must be put in place whereby each product, each variant and each version receives its own code — and that code is not accidentally assigned to another product. Those already working with GS1 codes, article numbers or serial numbers often already have the basis for this in place; those who do not must establish a new structure that is applied consistently, also for future product variants.
The code must functionally link the product and its passport to one another
This is not about a number on paper, but about a code that works functionally: scan or read the code, and the corresponding passport appears. Article 11 of the ESPR describes the technical requirements for the digital product passport as a whole, including the way in which passport, data carrier and identification code align with each other. For a company, this means that the identification code must not be separate from the QR code or other data carrier on the product — the two must together form a working whole. Those wondering what this coupling looks like in practice can find more background information at What is GS1 Digital Link and do I need it for the digital product passport?, a system that many companies already use to combine article codes and link structures.
The code must remain unique throughout the product's lifetime, even after sale, repair or resale
An identification code that is unique today must remain so throughout the entire lifespan of the product — even if the product changes owner, is repaired, or becomes part of a larger assembled product. For companies with multiple product lines or with products made up of components from different sources, this is a point where care is needed: a code that is internally reused for internal administration (for example, a batch number that is reissued after a period of time) is not suitable as a basis for the unique identification code of the passport. For products consisting of multiple parts that each need their own passport, the question of how those codes relate to each other arises; this is elaborated further at Does each component get its own passport or the product as a whole?.
The code must align with the register and with the data carrier on the product
The identification code does not function on its own: it must be recognizable in the passport itself, findable via the data carrier on the product, and consistent with what may be recorded in the European register. For a company, this means that the choice of an identification system is not only an IT matter, but also a registration matter. More on what must be recorded in this is at What is the register of digital product passports and what must I enter in it?. The physical side — how that code ends up on the product via the QR data carrier — is covered at How does the QR code for the digital product passport get onto my products?.
Where things go wrong in practice
A common situation is that a company uses its existing internal article number one-to-one as a unique identification code, without checking whether that number was ever reused for another product. Internal numbering systems are often not designed with a view to permanent uniqueness over many years, and this only becomes apparent once the passport is already linked.
A second situation arises with product variants: the same basic version with a minor change (different colour, different capacity, different size) sometimes does not receive its own code, with the result that the passport of one variant accidentally shows the passport of the other variant.
A third situation occurs with companies that manufacture under licence or across multiple production sites: if each site uses its own numbering system without central coordination, duplicate codes arise between sites, even though each site appeared to work consistently for itself.
A fourth situation is where the identification code exists, but does not match the data carrier actually affixed to the product — for example because the QR code has a different format or different link than the code used in the underlying systems. A company often only discovers this when a customer or supervisory authority actually scans the code and the product passport does not match.
A fifth situation arises with companies that link their product information to an external ERP or inventory system: when that system automatically generates new item numbers during inventory adjustments, the link to the original identification code of the product passport can be lost. How that link can be set up stably is described in Can I link the digital product passport to my ERP or inventory system?.
What you can document
- An overview of the chosen identification system: which number format, which length, which structure (for example based on GS1 or a proprietary structure), and why that system was chosen.
- An internal register or table in which each issued identification code is linked to the specific product, the product variant and the production site, so that duplicate assignment becomes traceable.
- A documented procedure for issuing new codes for new products or variants, including who within the company is responsible for that issuance.
- A control step in which it is documented that the identification code in the product passport, the code on the data carrier and the code in any internal systems actually match, before a product leaves the premises.
- Agreements on how codes are handled in case of repair, resale or assembled products, especially when multiple product passports are linked to each other — see also Can I link multiple digital product passports to each other?.
- Documentation of agreements with any software suppliers or ERP partners on maintaining the same identification code throughout the entire product lifecycle.
This is not legal advice. This page provides general information about the regulations that this platform concerns. We do not know your situation. If you are in doubt about your own case, consult a lawyer or the competent supervisory authority.
Written with AI on the basis of the sources above, checked by a human on 2026-08-22. Is something incorrect? Let us know — corrections are given priority.