Regulatory Guide
GS1 Digital Link — How QR Codes Connect Products to Passports
GS1 Digital Link — The Standard Behind DPP QR Codes
Every Digital Product Passport in the EU needs a way to connect the physical product to its digital data. The EU has chosen GS1 Digital Link as the standard to make this connection. If you are manufacturing products that will require a DPP, you need to understand what GS1 Digital Link is, how it works, and what you must implement to comply.
This guide explains the standard from first principles, covers the EU regulatory requirements, and walks through the practical steps of implementation.
What Is GS1 Digital Link
GS1 Digital Link is a standard developed by GS1, the global organisation responsible for product identification standards including barcodes and GTINs. It encodes existing GS1 product identifiers — such as the Global Trade Item Number (GTIN) — into a web URI (Uniform Resource Identifier). The result is a standardised URL that both humans and machines can use to access product information.
Before GS1 Digital Link, product identifiers and web addresses were separate systems. A barcode contained a GTIN. A website contained product information. There was no standardised way to link the two. GS1 Digital Link merges them into a single identifier that works as both a product code and a web address.
The standard was published as GS1 Digital Link Standard version 1.1 and has been adopted by the International Organization for Standardization as ISO/IEC DIS 18975. It is a mature, globally recognised standard — not a proposal or draft.
Why the EU Selected GS1 Digital Link for Digital Product Passports
The Ecodesign for Sustainable Products Regulation (ESPR), Regulation (EU) 2024/1781, requires every product with a DPP to carry a data carrier that links to the passport data. Article 9(6) of the ESPR specifies that the data carrier must comply with standards adopted by internationally recognised standardisation bodies. GS1 Digital Link satisfies this requirement.
The EU chose GS1 Digital Link for three reasons. First, interoperability. Every product in the EU single market, regardless of manufacturer or country of origin, will use the same identifier structure. This eliminates proprietary fragmentation and ensures that market surveillance authorities can read any product’s data carrier using standard tools. Second, global reach. GS1 operates in over 100 countries. Manufacturers outside the EU who export to the EU market can use the same standard they already use for their domestic supply chains. Third, machine readability. The URI structure is designed for automated processing by supply chain systems, customs systems, and market surveillance databases.
The Battery Regulation (Regulation (EU) 2023/1542) goes further. Article 77(3) explicitly mandates a QR code as the data carrier for battery passports. The QR code must encode a unique identifier that resolves to the passport data. GS1 Digital Link provides the standardised way to do this.
How GS1 Digital Link Works — The URI Structure
A GS1 Digital Link URI follows a specific structure that encodes the product identifier directly into the URL path. The canonical form is:
https://id.gs1.org/01/{GTIN}/21/{serial}
Breaking this down:
- https://id.gs1.org — The domain of the GS1 resolver (or your own resolver domain if you operate one). This is the base URL.
- /01/ — The GS1 Application Identifier for GTIN. “01” is the standard code that signals “the following digits are a GTIN.”
- {GTIN} — The 14-digit Global Trade Item Number that identifies the product type. For example, 09506000134352.
- /21/ — The GS1 Application Identifier for serial number. “21” signals “the following string is a serial number.”
- {serial} — The serial number that identifies the individual unit. For example, ABC12345.
A complete GS1 Digital Link URI looks like this:
https://id.gs1.org/01/09506000134352/21/ABC12345
This single URI uniquely identifies one specific product unit on the planet. It can be encoded into a QR code, printed on the product, and scanned by anyone with a smartphone. When scanned, the URI resolves to the product’s digital information — in the DPP context, the Digital Product Passport.
The domain does not have to be id.gs1.org. Manufacturers can use their own domain (e.g., https://id.yourcompany.com/01/{GTIN}/21/{serial}) as long as the URI structure follows the GS1 Digital Link syntax and the resolver conforms to the standard. This is known as a “custom domain resolver.”
The QR Code as Data Carrier
The GS1 Digital Link URI is encoded into a QR code that is affixed to the product. The QR code must comply with ISO/IEC 18004, the international standard for QR code symbology. This ensures that any standard QR code reader — including smartphone cameras — can decode the data.
The QR code serves as the physical bridge between the product and its digital data. When a consumer, repairer, recycler, or customs officer scans the code, their device reads the GS1 Digital Link URI, opens it in a browser, and the resolver directs them to the appropriate information.
For battery passports specifically, Article 77(3) of Regulation (EU) 2023/1542 mandates that the QR code be printed on or indelibly affixed to the battery. It must remain legible and scannable for the expected lifetime of the battery — which for EV batteries can be 10 to 15 years. This has implications for print durability, placement, and protection from environmental exposure.
Standard QR Code vs. GS1 Digital Link QR Code
A standard QR code can encode any text, URL, or data string. It has no inherent structure or semantic meaning. A QR code pointing to https://yourcompany.com/product/12345 is a valid QR code, but it is not a GS1 Digital Link QR code.
The difference is structure and interoperability. A GS1 Digital Link QR code encodes a URI that follows the standardised syntax, embedding the GTIN and serial number in a format that any GS1-compliant system can parse. A customs system scanning a GS1 Digital Link QR code can automatically extract the GTIN and serial number without any proprietary integration. A system scanning a standard QR code with a proprietary URL cannot.
For DPP compliance, the distinction matters. The ESPR and Battery Regulation require interoperability and standardised identification. A proprietary QR code that points to your website may work for consumers, but it will not satisfy the regulatory requirement for a standardised, machine-readable data carrier.
Resolver Architecture — How Scanning Routes to Information
When someone scans a GS1 Digital Link QR code, the URI is resolved by a resolver service. The resolver is a web server that receives the request and directs the user to the appropriate information based on context.
The GS1 Digital Link standard supports “link types” that allow a single URI to route to different content depending on who is asking and what they need. For example:
- A consumer scanning the code in a shop might be directed to a product information page showing key sustainability data, recycled content, and the carbon footprint class.
- A repairer scanning the same code might be directed to detailed technical specifications, dismantling instructions, and spare parts information.
- A market surveillance authority scanning the code might be directed to the full regulatory compliance dataset, including supply chain due diligence reports.
- A recycler scanning the code might be directed to material composition data and end-of-life handling instructions.
This routing is managed by the resolver through HTTP content negotiation and link type parameters defined in the GS1 standard. The resolver checks the request context — including authentication headers and link type parameters — and returns the appropriate response.
This architecture directly supports the tiered access model required by the Battery Regulation, where certain data is public, certain data is restricted to persons with a legitimate interest, and certain data is accessible only to authorities.
Relationship to ESPR and Battery Regulation Requirements
Article 9(1)(a) of the ESPR (Regulation (EU) 2024/1781) requires every DPP to contain a unique product identifier. Article 9(6) requires the product to bear a data carrier that is linked to the unique product identifier and provides access to the passport data. The data carrier must comply with ISO, CEN, CENELEC, or equivalent international standards.
GS1 Digital Link satisfies both requirements. The GTIN + serial number combination provides the unique product identifier. The QR code encoding the GS1 Digital Link URI provides the data carrier. The resolver provides the access mechanism.
The Battery Regulation adds specificity. Article 77(3) requires the data carrier to be a QR code. Article 77(4) requires the unique identifier to be registered in the electronic exchange system established under Article 78. The GS1 Digital Link URI, with its embedded GTIN and serial number, is designed to be registered in such systems.
For manufacturers subject to both the ESPR and the Battery Regulation, GS1 Digital Link provides a single, consistent identification and data carrier approach across all product categories.
Implementation — Step by Step
Implementing GS1 Digital Link requires several steps. None are optional if you intend to comply with EU DPP requirements.
1. Obtain a GS1 Company Prefix
If you do not already have a GS1 Company Prefix, contact your national GS1 Member Organisation to obtain one. The Company Prefix is the root from which all your GTINs are derived. Most manufacturers who sell through retail or distribution channels already have one. If you manufacture batteries or industrial components that have never carried barcodes, you may need to apply for the first time.
2. Assign GTINs to Your Products
Each distinct product model requires its own GTIN. If you manufacture three different battery models, you need three GTINs. The GTIN is a 14-digit number derived from your Company Prefix plus a product reference number and a check digit. GS1 provides tools to generate and manage GTINs.
3. Generate Serialised Identifiers
Each individual unit must have a serial number that, combined with the GTIN, creates a globally unique identifier. Your serialisation system must ensure that no two units ever share the same GTIN + serial number combination. For battery passports, this means every individual battery leaving your production line must receive a unique serial number.
4. Set Up a Resolver
You need a resolver that can receive GS1 Digital Link URIs and return the appropriate passport data. You can use the GS1 global resolver, operate your own resolver, or use a DPP platform that includes resolver functionality. The resolver must conform to the GS1 Digital Link resolver specification and support the link types required for DPP access tiers.
5. Generate and Print QR Codes
Using the GS1 Digital Link URI for each product unit, generate a QR code compliant with ISO/IEC 18004. The QR code must be printed or affixed to the product in a location that is accessible to the user, durable for the product’s expected lifetime, and scannable by standard smartphone cameras. For batteries, this means the code must withstand vibration, temperature variation, and potential chemical exposure over the full service life.
Printing and Placement Requirements
The QR code must be placed on the product itself. For batteries, this means on the battery casing. For consumer products under the ESPR, placement may also be on the packaging, provided the code on the product itself is also present or the delegated act permits packaging-only placement.
Durability is critical. A QR code that becomes unreadable after two years on an EV battery with a 15-year expected life does not comply. Use printing methods and materials that are rated for the full expected product life. Laser etching, durable labels with UV-resistant lamination, and direct part marking are common approaches for industrial products.
Size matters. The QR code must be large enough to be reliably scanned by a standard smartphone camera at a reasonable distance. GS1 recommends a minimum module size (the smallest square in the QR code) of 0.75mm, which typically results in a QR code of at least 20mm x 20mm depending on data length. Test with multiple devices and scanning conditions before finalising your print specifications.
How Traceable Handles GS1 Digital Link
Traceable generates GS1 Digital Link URIs and QR codes automatically for every product passport created on the platform. When you create a passport, the system assigns the serialised identifier, constructs the GS1 Digital Link URI, generates the compliant QR code, and hosts the resolver endpoint. The three-tier access control — public, legitimate interest, and authority — is managed through the resolver, routing each request to the appropriate data view based on the requestor’s authentication level.
This means you do not need to build or maintain resolver infrastructure yourself. The QR code is available for download in print-ready formats as soon as the passport is created.
Common Mistakes to Avoid
Several implementation errors are already emerging as companies begin preparing for DPP requirements. Avoid these.
Using Proprietary URLs Instead of GS1 Digital Link
Encoding a URL like https://yourcompany.com/passport/12345 into a QR code is not GS1 Digital Link. It may work functionally — scanning the code will open the page — but it does not satisfy the interoperability requirement. Customs systems and market surveillance tools expect GS1 Digital Link syntax. Proprietary URLs cannot be parsed by these systems without custom integration, which defeats the purpose of the standard.
Non-Serialised Codes
A QR code that encodes only a GTIN without a serial number identifies the product type but not the individual unit. The DPP requirement is at the unit level. Every individual product must have its own unique passport. A non-serialised code cannot link to a unit-level passport and does not comply.
Codes That Do Not Resolve
A QR code is only useful if scanning it returns the passport data. If the resolver is offline, the domain has expired, or the URL returns an error, the product effectively has no accessible passport. Ensure your resolver infrastructure — or your platform provider’s infrastructure — has the uptime, redundancy, and long-term commitment needed to serve passport data for the full lifetime of every product you place on the market.
Ignoring Print Durability
A QR code printed on a paper label that peels off after six months is a compliance failure. Test your QR code application method under real-world conditions — heat, cold, moisture, abrasion, UV exposure — before committing to production volumes.
The Future of GS1 Digital Link in the EU
GS1 Digital Link is positioned to become the universal product identifier across the EU single market. As ESPR delegated acts are adopted for additional product categories — textiles, electronics, furniture, construction products — each will require a data carrier linked to a DPP. GS1 Digital Link provides the consistent framework across all categories.
The standard also has implications beyond the DPP. Retailers are adopting GS1 Digital Link to replace traditional barcodes at point of sale. Supply chain operators are using it for traceability. Customs authorities are building it into border inspection systems. The investment you make now in GS1 Digital Link for DPP compliance will serve your broader digital supply chain strategy for years to come.
The European Commission has signalled that the central DPP registry, established under Article 12 of the ESPR, will use standardised unique identifiers compatible with GS1 Digital Link. Aligning with the standard now ensures that your products will integrate seamlessly with the central registry when it becomes operational.
Regulatory Status and Updates
This guide reflects the regulatory position as of March 2026 and is based on Regulation (EU) 2024/1781 (ESPR) and Regulation (EU) 2023/1542 (Battery Regulation) as published in the Official Journal of the European Union. Technical standards and implementing acts continue to evolve. Subscribe to Regulatory Radar on traceable.digital for updates as new specifications are published and compliance deadlines approach.