How it works
What a data carrier is, and which one you need
A data carrier is the QR code, Data Matrix code or radio tag on a product. The passport is the data behind it, and EU law names no symbol.
A data carrier is the printed code or the embedded tag that a scanner reads. European Union (EU) law does not tell you which carrier you need.
The digital product passport is the data that the code leads to. The ecodesign regulation names no symbol, and no ecodesign passport rule reaches any product group today.
Read that before you spend money. If you buy printers, tags or readers this year, you buy them against a rule that nobody can show you.
The carrier holds an address, and the passport holds the data
The two words describe different things.
A QR code on the label of an e-bike battery holds a short address. It does not hold the chemistry, the capacity or the recycled content. The passport at that address holds them. See what a digital product passport is.
One test separates them. Scan the code with a phone. The thing you scanned is the carrier, and the thing that came back is the passport.
A QR code, a Data Matrix code and a radio tag are all data carriers
GS1 uses the term data carrier for all three. In an apparel webinar in May 2026, GS1 named barcodes, radio frequency identification (RFID) and near field communication (NFC) as data carriers.
| Carrier | How the data comes off it |
|---|---|
| QR code | A camera or a scanner reads a printed two-dimensional code |
| Data Matrix code | A scanner reads a second type of printed two-dimensional code |
| RFID or NFC tag | A reader collects the data by radio, with no line of sight |
Three examples:
- a QR code on the swing tag of a merino jumper
- a Data Matrix code printed on the case of an e-bike battery
- an RFID tag sewn into a garment label
The identifier inside the carrier is a separate subject. See EN 18219, unique identifiers and how a passport works.
The ecodesign regulation names ISO/IEC 15459, and not the QR code
The Ecodesign for Sustainable Products Regulation (ESPR) is Regulation (EU) 2024/1781. It has been in force since 18 July 2024. Its Annex III, second paragraph, reads:
The data carrier, the unique product identifier ... shall, where relevant for the products concerned, comply with standards ISO/IEC 15459-1:2014 ... and ISO/IEC 15459-6:2014.
The paragraph names six parts of one standard series.
| Part | Edition named |
|---|---|
| ISO/IEC 15459-1 | 2014 |
| ISO/IEC 15459-2 | 2015 |
| ISO/IEC 15459-3 | 2014 |
| ISO/IEC 15459-4 | 2014 |
| ISO/IEC 15459-5 | 2014 |
| ISO/IEC 15459-6 | 2014 |
Article 10(1)(c) makes that an interim rule. It allows those standards, "or equivalent European or international standards until the references of harmonised standards are published".
A search of the full regulation returns no hit for these terms:
- ISO/IEC 18004, which is the QR code standard
- GS1
- Digital Link
- IEC 61406
- the digital object identifier (DOI)
So ESPR does not name a symbol at all. A supplier who tells you that the law demands a QR code, or a GS1 Digital Link web address, is wrong about the law. Your EU customer can still ask for either one as a condition of sale. See passport versus barcode.
The carrier goes on the product, the packaging or the documentation
ESPR requires the carrier to be physically present in one of three places. The places are the product, its packaging, and the documentation that goes with the product. Article 9(2) and Article 10(1) carry that rule.
The same articles leave the layout and the position to the delegated act for each product group. If the Commission adopts a delegated act for your product group, that act answers your carrier question. The Commission has adopted no such act, as at August 2026. See what a delegated act is and how to read the timeline.
ESPR Article 10(3) adds one duty about the carrier itself. The economic operator must give a dealer, or an online marketplace, a digital copy of the data carrier or of the unique product identifier. The copy costs the dealer nothing. The limit is five working days from the request. That duty starts only when a delegated act covers the product group.
All batteries get a QR code, but only three battery categories get a passport
The battery regulation is Regulation (EU) 2023/1542, and it is in force. It treats the code and the passport as two separate duties.
Article 13(6) gives all batteries a QR code. The rule sits in Annex VI Part C. That code leads to other information. It is not a passport.
Article 77(1) creates the passport duty, and it applies from 18 February 2027. It reaches three categories:
- each light means of transport (LMT) battery, such as an e-bike battery
- each industrial battery with a capacity greater than 2 kilowatt hours
- each electric vehicle battery
Warning: do not use the phrase "large batteries" to decide your position. A Commission news item of 20 July 2026 uses that phrase, and it is loose. A light means of transport battery carries no size threshold, and it is covered.
The Commission web page on digital product passports is loose in a second way. It writes "certain types of batteries, including", and that list is open. The three categories above are the full list. See batteries.
A torch battery thus carries the QR code and no passport. An e-bike battery carries the QR code and the passport. The code looks the same in both cases.
Two other EU laws do name a carrier, and one rules the QR code out
The answer to "which carrier" comes from the law that covers your product, and not from ESPR.
| Law | What it says about the carrier |
|---|---|
| Commission Delegated Regulation (EU) 2016/161, Article 5 | The unique identifier for a medicine goes in a two-dimensional Data Matrix with error detection and correction equivalent to or better than ECC200. A QR code does not satisfy this. |
| Regulation (EU) 2025/40, Article 12(5) | Where Union law already requires information through a data carrier, one carrier must serve the product information and the packaging information. The two must be easy to tell apart. |
Medicinal products sit outside ESPR, so the first row is not a passport rule. It shows that a European law can name a symbol. See medicinal products are excluded.
The second row reaches almost every exporter, because almost every product has packaging. It asks for one code on the box, and not for two. See packaging.
This site cannot tell you which carrier to choose
EN 18220:2026 is titled "Digital product passport - Data carriers". The Commission cited it in the Official Journal in July 2026.
A title is not a scope statement. The full text is paywalled, at between 190 and 370 EUR, and this site has not bought it.
So this site states nothing about which carriers EN 18220 permits. It states nothing about the size, the position or the print quality either. Treat any such claim as unverified until the person quotes the purchased text. See EN 18220 and why the texts are paywalled.
Citation does not make the standard mandatory. It gives a product built to the standard a presumption of conformity.
Industry has not answered the question either. GS1 started an apparel subgroup in May 2026. Its open items include where to place a code, how to mark a product permanently, and how durable the mark must be.
Do not buy hardware yet, but scope the decision now
Warning: do not buy printing or tagging equipment to meet a standard that nobody has shown you.
A carrier decision is a production line decision. It touches artwork, label stock, print equipment and the packaging cycle. Those changes take months, so scope the decision early and buy late.
- List every place a code could go: swing tag, case marking, carton, manual.
- Ask your EU customer which carrier they read at goods-in, and in what format.
- Ask each equipment supplier which standard the kit meets, by number.
- Ask that supplier to quote the clause, and to name the purchased document.
- Keep one identifier behind every carrier you apply.
- Change the artwork at your next packaging refresh, and not in a special print run.
The last step comes from GS1 UK. Camilla Young of GS1 UK spoke to the Institute of Grocery Distribution in March 2026, about the move to two-dimensional barcodes. She told the grocery industry to use natural packaging cycles, and not to wait for a cut-over announcement.
You print the code in New Zealand. The passport duty sits with the economic operator that places the product on the EU market. If you have no EU establishment, that operator is usually your EU importer. Agree in writing who supplies the code artwork and who owns the identifier. See agreeing data duties with your EU importer and what this means for New Zealand exporters.