What is GS1 Digital Link and do I need it for the digital product passport?

What you must do concretely

What is expected of you

GS1 Digital Link is not a separate legal requirement standing apart from the ESVPR — it is a technical standard for how a barcode or QR code refers to information on the internet. The ESVPR prescribes what the data carrier and identification code must comply with; GS1 Digital Link is a way of implementing that which aligns with existing barcode systems. For a production company, this means the question "do I need this" actually consists of two parts: what does the ESVPR require, and which technical route do you choose to comply with it.

A unique identification code per product

Article 12 of the ESVPR (Regulation (EU) 2024/1781) requires a unique identification code by which a product can be traced back to its corresponding passport. This code must be structured in a way that is machine-readable and remains consistently linked to one passport. For a company with 10 to 100 employees, this means in practice that there must be a system by which each product — or each batch, depending on the product group — receives its own code that is not reused anywhere else. Companies that already work with GS1 barcodes (GTINs) have a head start here, because that identification structure can be extended relatively easily to a passport reference. How exactly that unique code is structured and assigned is described on the page about how you give each product a unique identification code.

A data carrier that refers to the passport

Article 11 of the ESVPR describes the technical design and operation of the digital product passport, including the requirement that the passport is accessible via a data carrier on the product — in practice usually a QR code. That data carrier must be designed such that scanning it leads directly to the correct, up-to-date passport page. GS1 Digital Link is precisely that: a URL structure that fits in a QR code and that can be read both by an ordinary smartphone camera and by professional scanning systems. The practical difference from a "bare" URL is that Digital Link provides room to also include the GTIN, a batch number or a serial number within the same code, so that a single scan refers immediately to the correct product instance rather than to a generic product page. More about the technical side of applying this code is on the page about how the QR code for the product passport comes onto the product.

Ensuring the link keeps working

The link between code and passport must not only work at launch, but throughout the entire period that the passport must be available. That requires a technical choice that does not depend on a system that the company manages itself and that could disappear in a system change, takeover or discontinuation. For companies that want to determine themselves how the underlying data is supplied and maintained, it is relevant how that interacts with a link to your own ERP or inventory system: GS1 Digital Link determines the form of the reference, not where and how the underlying data is managed.

Where things go wrong in practice

A number of recurring situations at companies that are implementing GS1 Digital Link:

The QR code refers to a marketing page instead of to the passport. Many companies already have a QR code on the packaging that leads to their own website. Reusing that code for the passport without adapting the underlying structure results in a data carrier that does not comply with the requirement of Article 11, because the link does not refer to the required passport content.

One GTIN for multiple variants. If a product group is required to have a passport per variant (colour, power, composition) but the company internally works with one item code for the entire product line, a mismatch arises between the barcode and the required unique identification code per product.

Digital Link implemented, but not tested with existing scanning equipment. Some older scanners in your own logistics or at trading partners do not recognize the new URL structure correctly, causing the code to be scannable for a smartphone but not in your own supply chain.

The reference is hardcoded to a specific server location. When the link points directly to an internal system without an intermediary layer, a problem arises as soon as that system is replaced — the QR codes on products already in commerce cannot be adjusted.

Confusion between batch level and product level. For products for which batch data are relevant (such as composition or origin of materials), the identification code is sometimes recorded at product level while the passport content differs per batch, which leads to incorrect or incomplete information when scanning.

What you can document

• An overview of which product types, variants or batches require their own unique identification code, and how this relates to existing GTINs or article codes.
• The technical specification of the chosen data carrier (Digital Link structure, QR code format, which identifying data are included in it).
• A test report documenting that the QR code scans correctly with both consumer devices and any scanning systems in your own logistics chain.
• Agreements with the hosting party on what happens if the underlying system location changes, so that already issued QR codes continue to work — relevant in combination with the question how long a product passport must remain available.
• A procedure for what happens in case of a damaged or unreadable code on a product already with a customer, see also the page on what to do if the QR code is damaged or unreadable.
• Documentation of the assigned identification codes per product or batch, including a reference to the associated passport, so that this remains traceable even after staff changes.