The Digital Product Passport conversation is dominated by data models, but the QR code on the physical product is what an inspector, a recycler, or a consumer actually scans. The standard that defines how that QR code is structured matters. The most relevant update for operators in 2026 is that GS1 Digital Link has been published as an international standard — ISO/IEC 18975 — and the GS1 community has been issuing implementation material aimed specifically at DPP use cases.
What ISO/IEC 18975 actually does
GS1 Digital Link was first published by GS1 in 2018, with version 1.2 released in January 2021, and has since been adopted as ISO/IEC 18975. The standard describes a method for combining globally unique identifiers — for example a Global Trade Item Number (GTIN) — with a URL path structure, so that a single web URI encoded in a QR code can both identify the product and resolve to digital information about it.
In practical terms, a Digital Link URI looks like a normal HTTPS URL with structured path segments such as /01/<GTIN> for the product identifier and optional segments for batch, serial, or expiry. Any compliant scanner can extract the identifier; any browser can follow the URL.
What EU regulation actually requires
It is important to separate the standard from the legal mandate. Two pieces of EU legislation are directly relevant:
- Regulation (EU) 2023/1542 (Batteries). Article 13 requires labelling and a QR code on every battery placed on the EU market. Article 77 requires a battery passport, accessible via the QR code data carrier, applying from 18 February 2027 to electric vehicle batteries, LMT batteries, and industrial batteries above 2 kWh.
- Regulation (EU) 2024/1781 (ESPR). Article 9 allows delegated acts to mandate a DPP per product group; Article 10 deals with data carriers. Specific carrier requirements will be set in each product-group delegated act.
Neither regulation names GS1 Digital Link as the sole permitted standard. The Battery Regulation requires a QR code; it does not specify the URI syntax inside it. ESPR delegates the carrier specification to the implementing measures. GS1 Digital Link is a leading industry candidate — and is referenced in GS1’s own DPP-oriented publications — but it is not legally mandated by name in EU primary legislation as of June 2026.
Recent GS1 implementation material
GS1 has published a series of DPP-oriented documents over 2024–2025, including “GS1 Standards Enabling the EU Digital Product Passport” and “Implementation Considerations for Unique DPP Product Identifiers” (GS1 in Europe, 2025). These describe how GTIN, GS1 Digital Link, and resolver infrastructure can be combined to satisfy the unique-identifier and machine-readable carrier expectations in EU regulations. GS1 has also published a Digital Product Passport provisional standard and run a public review process for further DPP-specific guidance.
These are industry publications, not legislative text. They are useful for design choices today, but they do not override or substitute for the implementing acts the Commission will adopt.
What operators should do now
- Confirm your product carries a licensed GTIN. Without one, no Digital Link URI is conformant.
- Standardise on HTTPS resolvers under your own controlled domain — Article 77 of Reg 2023/1542 requires the passport to remain accessible for the regulated retention period.
- Design the QR for compatibility with both DPP resolution and existing point-of-sale and inspector scanning. ISO/IEC 18975 is engineered for this dual use.
- Watch for the carrier specification in forthcoming ESPR delegated acts and in any Commission implementing act under Article 77 of the Battery Regulation. If a carrier is mandated by name there, that becomes the binding reference.
Where Traceable sits
Traceable supports GS1 Digital Link QR codes today. Every published passport on the platform is reachable via a GS1-conformant /01/<GTIN> path in addition to its slug URL, so a single QR code can serve both retail and DPP use cases.
Primary sources: Regulation (EU) 2023/1542 (EUR-Lex); Regulation (EU) 2024/1781 (EUR-Lex); ISO/IEC 18975 (ISO catalogue); GS1 Digital Link (GS1); GS1 in Europe, Implementation Considerations for Unique DPP Product Identifiers, 2025 (GS1 EU).
