If you are preparing a battery passport for the EU market, you have probably encountered the term “GS1 Digital Link battery passport” in supplier conversations or industry forums. This article explains what Regulation (EU) 2023/1542 actually mandates for QR codes and unique identifiers, where GS1 Digital Link fits in, and what you need to decide before your compliance deadline.
What the Regulation Says About QR Codes
Article 77(3) of Regulation (EU) 2023/1542 requires the battery passport to be accessible through a QR code. That QR code must link to a unique identifier. Both the QR code and the unique identifier must comply with the ISO/IEC 15459 series, specifically parts 15459-1:2014, 15459-2:2015, 15459-3:2014, 15459-4:2014, 15459-5:2014, and 15459-6:2014, or their equivalents.
Article 13(6) of the same regulation requires batteries to bear a QR code, and Article 13(7) requires it to be printed or engraved visibly, legibly and indelibly on the battery, or affixed to the packaging and accompanying documents where the nature and size of the battery do not allow that. This is not a one-time labelling task. The code must survive the full operational life of the product.
The QR symbology used in practice is the international QR Code symbology defined by ISO/IEC 18004:2015. That standard is industry norm and is not named in Regulation (EU) 2023/1542. It defines how the black-and-white squares are encoded and read, and is separate from the identifier standards named in Article 77(3).
What the Regulation Does Not Say
The words “GS1” and “Digital Link” do not appear anywhere in Regulation (EU) 2023/1542. GS1 Digital Link is an industry standard, not a legal requirement. The regulation specifies ISO/IEC 15459 compliance for the unique identifier, and it leaves the choice of issuing agency to the manufacturer.
This distinction matters. You are not legally required to use GS1. You are required to use an identifier that meets ISO/IEC 15459. GS1 is one of the recognised issuing agencies under that standard, which is why a GS1-issued identifier satisfies Article 77(3). Other ISO/IEC 15459-recognised agencies also produce compliant identifiers.
How GS1 Digital Link Works in a Battery Passport QR Code
GS1 Digital Link encodes a URL inside the QR code. That URL contains the product identifier and resolves to the battery passport when scanned. The primary identifier in a GS1 Digital Link QR code is the GTIN, the Global Trade Item Number, a 14-digit number that GS1 assigns to a specific battery model.
The URL structure uses the application identifier prefix /01/ for the GTIN. A typical GS1 Digital Link URL looks like this: https://domain.com/01/09521234543213. The domain is controlled by the manufacturer or their service provider. The /01/ segment tells any GS1-aware resolver that what follows is a GTIN.
A plain-URL QR code, one that simply encodes a web address without a structured identifier, is not the same thing as a GS1 Digital Link QR code. Either approach can be compliant with Article 77(3), provided the underlying unique identifier meets ISO/IEC 15459. The QR code is the carrier; the identifier is what the regulation governs.
For a fuller technical explanation of how the URL structure resolves to product data, see GS1 Digital Link explained.
The GS1 Digital Link Battery Passport Route: What You Need
If you choose the GS1 route, you need two things before you can generate compliant QR codes.
- A GS1 Company Prefix. This is a number block licensed to your organisation by your national GS1 member organisation. The prefix length determines how many GTINs you can create.
- GTINs assigned to your battery models. Each distinct battery model gets its own GTIN. You build the 14-digit GTIN from your company prefix plus a product reference number and a check digit.
Manufacturers using a different ISO/IEC 15459-recognised issuing agency do not need a GS1 Company Prefix or GTINs. They obtain identifiers through whichever agency they choose, provided that agency is recognised under the ISO/IEC 15459 series.
The Digital Product Passport Registry
The QR code on the battery links to a unique identifier, but that identifier also needs to be registered somewhere. Article 13(1) of the Ecodesign for Sustainable Products Regulation (ESPR) requires the European Commission to set up a digital product passport registry by 19 July 2026. That registry will store the battery unique identifiers referred to in Article 77(3) of Regulation (EU) 2023/1542.
The registry is a Commission-run infrastructure, not a private database. When a market surveillance authority or an authorised party scans a battery QR code, the identifier resolves through this registry to the battery passport data. The Commission has not yet published the full technical specification for how manufacturers will submit identifiers to the registry. Watch for delegated acts and implementing acts under ESPR for those details.
Access Tiers and What the QR Code Unlocks
Not all battery passport data is visible to everyone who scans the QR code. Annex XIII of Regulation (EU) 2023/1542 organises data access into four numbered points.
- Annex XIII point 1 covers data accessible to the general public. This includes the information listed in Annex VI Part A, such as battery model, chemistry, and capacity.
- Annex XIII point 2 covers data accessible to persons with a legitimate interest and to the Commission.
- Annex XIII point 3 covers data accessible to notified bodies and market surveillance authorities.
- Annex XIII point 4 covers individual-battery data accessible to persons with a legitimate interest.
The QR code on the battery gives any scanner access to the point 1 public data. Access to points 2, 3, and 4 requires authentication. Your passport system must enforce these tiers from the moment the passport goes live.
Compliance Deadlines
The battery passport requirement applies to electric vehicle (EV) batteries, light means of transport (LMT) batteries, and industrial batteries with a capacity above 2 kWh. Article 77(1) of Regulation (EU) 2023/1542 sets a single applicability date of 18 February 2027 for all three categories. Implementing and delegated acts on access-tier persons (Article 77(9), due 18 August 2026) and on Annex XIII data content are still expected, and may alter access-control and content details, but they do not change the 18 February 2027 applicability date set in the regulation itself.
The European Commission’s guidance enumerates 71 data points in total across battery categories: 47 are mandatory and required at the February 2027 deadline for EV batteries, 50 for LMT batteries, and 32 for industrial batteries above 2 kWh. These are data points as defined by Commission guidance, not a count of fields in Annex XIII.
Practical Steps for Manufacturers
The following sequence covers the minimum actions needed to reach QR code compliance under Article 77(3).
- Decide which ISO/IEC 15459-recognised issuing agency you will use. If you choose GS1, apply for a GS1 Company Prefix through your national GS1 member organisation.
- Assign a unique identifier to each battery model (and, where required by the regulation, to each individual battery unit).
- Generate QR codes that encode those identifiers using the standard QR Code symbology (ISO/IEC 18004:2015, industry norm rather than a requirement of the regulation).
- If you use GS1 Digital Link, structure your URLs using the /01/ application identifier prefix for the GTIN, pointing to a resolver that returns the battery passport.
- Ensure the QR code is printed on the battery, label, or packaging in a way that remains legible for the full battery lifecycle, as required by Article 13(6).
- Register your unique identifiers with the Commission registry once the registry is operational. The ESPR Article 13(1) deadline for the registry is 19 July 2026, but the technical submission process is not yet confirmed.
- Implement access-tier controls so that public data is available without authentication and restricted data requires verified credentials, in line with Annex XIII points 1 through 4.
Choosing Between GS1 and Other Issuing Agencies
GS1 Digital Link has one practical advantage: the GTIN is already the global product identifier used in retail supply chains. If your battery is also sold as a consumer product, your logistics and retail partners likely already use GTINs. Adopting GS1 Digital Link means one identifier serves both supply chain and regulatory purposes.
The disadvantage is cost and administration. GS1 Company Prefix licences carry an annual fee that scales with the number of GTINs you need. Manufacturers with a small battery portfolio and no existing GS1 relationship may find another ISO/IEC 15459 issuing agency more practical.
Neither choice is legally superior under Regulation (EU) 2023/1542. Article 77(3) requires ISO/IEC 15459 compliance, not GS1 compliance. In practice Traceable supports GS1 today; if your programme requires a different ISO/IEC 15459 issuing agency, talk to us. Make the decision based on your supply chain context and your existing identifier infrastructure.
If you want to see how Traceable maps these requirements to a working battery passport, visit traceable.digital/pricing to start a free trial. The platform covers identifier registration, access-tier enforcement, and QR code generation in one place.
