How it works
The EU does not require a GS1 Digital Link
GS1 Digital Link writes a product identifier as a web address. The EU ecodesign regulation does not name it anywhere in its text.
GS1 Digital Link puts the number under a retail barcode into a web address. The European Union (EU) does not require it.
Read this before you buy anything. A supplier can tell you that EU law forces your QR code to hold a GS1 Digital Link address. You then pay for a service to meet a rule that the legal text does not contain. You also repeat that rule to your EU customer, who cannot find it either.
GS1 Digital Link writes a product number into a web address
GS1 is the standards body behind the barcode on a retail product. GS1 describes itself as a neutral, not-for-profit organisation. GS1 states that it sells no printing, no labelling and no IT systems. GS1 also states that it is not a legal advisor.
The number under a retail barcode is the Global Trade Item Number (GTIN). A merino jumper has one. A carton of wine has one. See what a GTIN is and product identifiers.
GS1 Digital Link writes that number into a web address. The code on the product then holds an address, and a scan calls it. The address can carry more than the product number. It can also carry a batch number and a serial number, in a path of this shape:
/01/<product number>/10/<batch>/21/<serial>
The reasons to choose it are commercial, not legal
One code can then answer two callers. A person gets a page to read. A machine gets structured data. The service at the other end reads the request and decides which answer to send. See what a resolver is and content negotiation.
A supermarket till can read the same code, but only after the till can read a two-dimensional code. GS1 UK gives 2027 as the milestone for most retail checkout systems to read two-dimensional codes. That milestone is an industry target, and it is not a law. Until a till can read the new code, a pack usually carries the linear barcode as well. See how a passport differs from a barcode.
Each reason above is a commercial reason. The problem is the legal reason that people add to them.
The ecodesign regulation does not name GS1 Digital Link
The EU law that creates the digital product passport is the Ecodesign for Sustainable Products Regulation (ESPR), Regulation (EU) 2024/1781. It has been in force since 18 July 2024.
A case-insensitive search covered the full text: the recitals, the 79 articles and every annex. Each of these terms returns zero hits:
- GS1
- Digital Link
- IEC 61406
- digital object identifier (DOI)
- decentralised identifier
- ISO/IEC 18004, which is the QR code standard
So the regulation names no web address form, and it does not name the QR code either.
The regulation names the ISO/IEC 15459 series instead
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, ISO/IEC 15459-2:2015, ISO/IEC 15459-3:2014, ISO/IEC 15459-4:2014, ISO/IEC 15459-5:2014 and ISO/IEC 15459-6:2014.
Annex III(c) names the GTIN under part 6 of that series. The law names your GS1 product number, though not the address form around it.
| Item | Where it sits in the ESPR | Status |
|---|---|---|
| The ISO/IEC 15459 series, parts 1 to 6 | Annex III, second paragraph | In force since 18 July 2024 |
| The GTIN, under part 6 | Annex III(c) | In force since 18 July 2024 |
| The interim rule | Article 10(1)(c) | In force since 18 July 2024 |
Two limits sit inside that rule. The words "where relevant for the products concerned" make it conditional. Article 10(1)(c) then allows those standards, "or equivalent European or international standards until the references of harmonised standards are published".
So this is an interim rule, and it points at a series of ISO/IEC standards, not at a vendor scheme. See EN 18219, unique identifiers.
Two standards could name it, and nobody here has read them
The European Commission cited six European standards for the passport in Implementing Decision (EU) 2026/1736. That Decision has been in force since 15 July 2026, and you can read it in the Official Journal.
The table below names the six. There is no EN 18217 and no EN 18218.
| Standard | Official title |
|---|---|
| EN 18216 | Digital product passport - Data exchange protocols |
| EN 18219 | Digital product passport - Unique identifiers |
| EN 18220 | Digital product passport - Data carriers |
| EN 18221 | Digital product passport - Data storage, archiving, and persistence |
| EN 18222 | Digital Product Passport - Application Programming Interfaces (APIs) for product passport lifecycle management and searchability |
| EN 18223 | Digital Product Passport - System interoperability |
The capitalisation changes between the titles. That change is in the official text.
Two of them could touch this question. EN 18219 covers unique identifiers. EN 18220 covers data carriers.
Warning: each standard costs 190 to 370 euros on the distributor listings, and this site has bought no copy. So this site states nothing about which identifier schemes EN 18219 permits, and nothing about which carriers EN 18220 permits.
Many pages state that EN 18219 permits a set number of product identifier schemes, and they name GS1 Digital Link among them. This site searched the commentary that carries the count, and none of it quotes the standard. So the count stays unverified here. See identifier schemes: what is verified and why the texts are paywalled.
One more limit belongs here. The search above covered the ESPR. It did not cover every other EU law, so this page says nothing about what another regulation names.
Citation would not settle the question in any case. Citation in the Official Journal gives a product built to a standard a presumption of conformity. The standard stays voluntary, and you may meet the legal requirement another way.
Your customer can require it, and that is a contract
An EU buyer can make a GS1 Digital Link address a condition of sale. A retailer can do the same. Neither one needs a law behind the request.
Treat such a request as a commercial term. Put it in the contract, and name the party that supplies each number and each address. See agreeing data duties.
No ESPR passport duty applies to any product today
The ESPR is a framework. A passport duty reaches a product group only through a delegated act for that group. As at 14 August 2026 the Commission has adopted no such act for any group.
One passport duty is real, and it comes from a different law. Regulation (EU) 2023/1542 is the battery regulation, and it is in force. Article 77 applies from 18 February 2027. Three categories then need a passport:
- 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
Read how to read the timeline before you accept any date from a supplier.
Four checks on a supplier claim
- Ask which document requires this address. Get the name of the document.
- Ask which article or clause requires it. Get the quotation.
- Do not accept the ESPR as the answer. The text does not carry it.
- If the real answer is a purchase condition, write it into the contract.
Keep your GTIN work, and choose the address form on its merits
Keep the GTIN work you already do. The regulation names the GTIN, so clean number allocation helps whatever comes next.
Choose the address form on its merits. Three points decide it:
- the request your EU customer puts in writing
- the data your own systems can hold and update
- the work the code on the product must do at a till
Do not buy it because somebody quotes the regulation at you. Ask for the document, and check the article. See what this means for New Zealand exporters.