Product Identification Standards for ESPR Compliance

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The Foundation of Digital Product Passports: Product Identification

At the heart of every Digital Product Passport lies a product identifier, a unique code that links a physical product to its digital record. Without robust, standardised identification, the entire DPP system cannot function. Products cannot be distinguished from one another, traceability chains break down, and passport data cannot be reliably associated with the correct items.

The EU's Ecodesign for Sustainable Products Regulation establishes clear requirements for product identification within Digital Product Passports. These requirements draw heavily on existing GS1 standards, which have been the global foundation for product identification in supply chains for over five decades. Understanding these standards and how they apply to ESPR compliance is essential for any business that will need to issue Digital Product Passports.

This article examines the product identification standards relevant to ESPR compliance, explains the different levels of identification granularity, and provides practical guidance for businesses preparing their identification infrastructure for DPP readiness.

GTIN: The Global Trade Item Number

The GTIN (Global Trade Item Number) is the cornerstone of product identification worldwide. Managed by GS1, GTINs are assigned to products by their brand owners and serve as the primary product-level identifier in commerce. Every product with a barcode on a shop shelf has a GTIN encoded within it.

GTINs come in several formats, GTIN-8 (8 digits), GTIN-12 (12 digits, also known as UPC), GTIN-13 (13 digits, also known as EAN), and GTIN-14 (14 digits, used for trade and logistics units). For DPP purposes, GTIN-13 and GTIN-14 are the most commonly used formats, though all formats are valid GS1 keys.

A GTIN identifies a product at the model or SKU level, it tells you what the product is (brand, type, size, colour variant) but does not distinguish between individual instances of the same product. Two identical t-shirts in the same size and colour would share the same GTIN. This level of identification is sufficient for some DPP use cases but insufficient for others.

Obtaining GTINs requires membership of a GS1 member organisation. In the United Kingdom, this is GS1 UK. Membership provides a GS1 Company Prefix from which the business can allocate GTINs to its products. For businesses that do not yet have GTINs, this is the essential first step towards DPP readiness.

It is important to note that GTINs must be allocated following GS1 allocation rules. Each distinct product configuration, differing in any attribute that is relevant to trade, must receive its own GTIN. This ensures that GTINs are globally unique and unambiguous, which is a prerequisite for their use as DPP identifiers.

Serialisation: Individual Product Identity

While GTINs identify product types, many DPP requirements demand identification of individual product instances. The ESPR explicitly requires that Digital Product Passports include a unique product identifier, a code that identifies not just what the product is, but which specific unit it is. This is achieved through serialisation.

Serialisation combines a GTIN with a serial number to create a unique identity for each individual product. In GS1 terminology, this combination is known as an SGTIN (Serialised GTIN). The GTIN provides the product-level context, and the serial number provides the instance-level distinction. Together, they guarantee global uniqueness, no two products anywhere in the world will share the same GTIN plus serial number combination.

The serial number component can be alphanumeric and up to 20 characters in length. Brand owners have flexibility in how they generate serial numbers, sequential, random, or algorithmically derived approaches are all valid, provided each serial number is unique within the scope of its parent GTIN.

Serialisation has significant implications for manufacturing and logistics processes. Production lines need to be equipped to assign, print, and verify unique identifiers on every individual product. Data systems need to track these serial-level identities throughout the supply chain. For industries such as pharmaceuticals and tobacco that already operate under serialisation mandates, this infrastructure exists. For other sectors, serialisation may represent a substantial new capability requirement.

The level of serialisation required varies by product category under the ESPR. Some delegated acts may require item-level serialisation, while others may accept batch-level identification. Businesses should monitor the development of delegated acts for their product categories to understand the specific serialisation requirements they will need to meet.

GS1 Digital Link: Web-Native Product Identification

Traditional GS1 identifiers are numeric codes designed for barcode encoding and supply chain data exchange. They are efficient for machine processing but not directly usable on the web. The GS1 Digital Link standard bridges this gap by defining a URI (Uniform Resource Identifier) structure that embeds GS1 identifiers within a web-addressable format.

A GS1 Digital Link URI takes the form: https://id.gs1.org/01/05012345678901/21/ABC123, where 01 indicates a GTIN, 05012345678901 is the GTIN value, 21 indicates a serial number, and ABC123 is the serial number value. This URI can be resolved through standard web infrastructure to access the product's Digital Product Passport.

For ESPR compliance, GS1 Digital Link provides the critical bridge between the physical product identifier (encoded in a QR code, NFC tag, or RFID tag) and the digital passport data (hosted on a web server or in a DPP registry). When a consumer, inspector, or recycler scans the data carrier, the GS1 Digital Link URI directs them to the appropriate passport content.

The resolver architecture behind GS1 Digital Link deserves particular attention. A Digital Link resolver is a web service that receives a GS1 Digital Link URI and redirects the request to the appropriate information source. This indirection layer is important because it allows the location of passport data to change over time without requiring the physical data carrier on the product to be updated. If a company migrates its DPP system to a new platform, it simply updates the resolver, the QR codes already on products continue to work.

GS1 Digital Link also supports content negotiation, allowing the same URI to return different representations depending on the requester. A consumer's smartphone might receive an HTML page, a regulatory system might receive JSON-LD structured data, and a supply chain system might receive GS1 EPCIS event data. This flexibility makes a single identifier serve multiple audiences and use cases simultaneously.

Batch and Lot Identification

Not all products require item-level serialisation. For many product categories, batch or lot identification provides an appropriate level of granularity for DPP purposes. A batch number identifies a group of products manufactured together under the same conditions, sharing the same material inputs and process parameters.

In GS1 standards, batch or lot identification is represented by Application Identifier (AI) 10, which can be combined with a GTIN to create a unique batch-level identity. The GS1 Digital Link URI for a batch-identified product would include the lot parameter: https://id.gs1.org/01/05012345678901/10/LOT2024A.

Batch identification is particularly relevant for process-manufactured products, chemicals, paints, food ingredients, construction materials, where production occurs in continuous or semi-continuous runs rather than as discrete items. For these products, material composition, test results, and environmental impact data are consistent within a batch, making batch-level DPPs both practical and meaningful.

The choice between item-level and batch-level identification depends on the specific delegated act requirements for each product category, the nature of the product, and the business value of granular tracking. Where the delegated act permits batch-level identification and the product characteristics support it, batch identification significantly reduces the complexity and cost of DPP implementation compared to full serialisation.

Businesses should be prepared for the possibility that identification requirements may tighten over time. Even if initial delegated acts permit batch-level identification, subsequent revisions could require item-level serialisation. Building identification systems that can accommodate both levels of granularity provides valuable future-proofing.

Additional GS1 Identifiers for DPP Ecosystems

Beyond GTINs and serial numbers, several other GS1 identifiers play important roles in DPP ecosystems:

• GLN (Global Location Number), identifies physical and digital locations such as factories, warehouses, and retail outlets, providing the "where" dimension for traceability data
• SSCC (Serial Shipping Container Code), identifies individual logistics units such as pallets and cases, supporting the tracking of products through distribution channels
• GRAI (Global Returnable Asset Identifier), identifies returnable and reusable assets such as containers and pallets, relevant for circular economy tracking
• GDTI (Global Document Type Identifier), identifies documents such as certificates, test reports, and compliance declarations that may be referenced within DPPs
• LGTIN (GTIN + Batch/Lot), combines the GTIN with a batch or lot number for batch-level product identification

These identifiers work together to create a comprehensive identification framework that can represent not just products but the entire ecosystem of locations, logistics units, assets, and documents that contribute to a product's Digital Product Passport. The consistency and interoperability of this GS1 identification system is one of its greatest strengths, all of these identifiers follow the same structural principles and can be encoded in the same data carriers.

For businesses implementing DPPs, establishing a complete GS1 identification infrastructure, covering products, locations, logistics units, and documents, provides the foundation for comprehensive traceability. Partial adoption of GS1 identifiers creates gaps in the data chain that undermine the integrity of the Digital Product Passport.

Aligning Product Identification with ESPR Requirements

The ESPR framework establishes general principles for product identification within Digital Product Passports, while the specific requirements for each product category are defined in delegated acts. However, several cross-cutting identification requirements are clear from the regulation itself:

• Every product with a DPP must have a unique product identifier that is globally unambiguous and machine-readable
• The identifier must be encoded in a data carrier that is physically associated with the product
• The data carrier must comply with ISO and international standards for automatic identification
• The identifier must enable access to the product's passport data through a digital registry or resolver
• Product identification must support the product's traceability throughout its lifecycle, including second-hand markets and end-of-life processing

These requirements map naturally to the GS1 identification system: GTINs with serial numbers for unique product identification, GS1 Digital Link for web-resolvable URIs, standardised data carriers (QR codes, RFID, NFC) for physical encoding, and resolver infrastructure for persistent access to passport data.

Businesses that have already adopted GS1 identification for their existing supply chain operations have a significant head start in ESPR compliance. Those that have not should engage with their GS1 member organisation to begin the process of obtaining identifiers and establishing the master data management practices needed to maintain identifier quality and consistency.

Practical Steps Towards Identification Readiness

Preparing your product identification infrastructure for ESPR compliance is a practical, step-by-step process. The following roadmap provides a structured approach:

• Audit your current identification practices, do all your products have GTINs? Are they correctly allocated following GS1 rules? Is your product master data clean and up-to-date?
• Assess serialisation readiness, can your production lines assign and verify serial numbers on individual products? What process changes would be needed?
• Evaluate data carrier options, which technology (QR code, RFID, NFC) best serves your products, consumers, and supply chain?
• Plan your GS1 Digital Link implementation, will you use a hosted resolver service, a GS1-provided resolver, or build your own?
• Engage with supply chain partners, ensure that your suppliers and logistics providers can work with serialised identifiers and contribute traceability data

Platforms such as MyProductPassport simplify many of these steps by providing integrated identifier management, QR code generation, and Digital Link resolution as part of a complete DPP solution. By handling the technical complexity of identification and resolution, these platforms allow businesses to focus on gathering and publishing the product data that makes their Digital Product Passports genuinely useful.

Product identification may seem like a dry technical topic, but it is the foundation upon which the entire Digital Product Passport ecosystem is built. Getting identification right from the outset avoids costly rework later and ensures that your DPPs are interoperable, verifiable, and compliant from day one.