Foundations
How a digital product passport differs from a barcode
A barcode identifies a product. A digital product passport describes one, and EU law sets different rules for each.
A barcode identifies your merino jumper. A digital product passport describes it.
That difference decides what you must build. If you print a new code on your merino jumper and stop there, you hold an identifier and no passport. An identifier on its own does not meet a passport rule.
Read this before you spend money. No European Union (EU) passport rule applies to any product today. The first one is a battery rule, and it applies from 18 February 2027.
A retail barcode holds one number, and that number names the model
The barcode on a carton of wine at a supermarket checkout holds a Global Trade Item Number (GTIN). Some people call the same number the Universal Product Code (UPC).
A retail linear barcode carries the identifier and nothing else. The price is not in the code. The till reads the number and finds the price in the retailer's own system.
The number names the model, not the item. Two identical e-bike batteries from one production run carry the same GTIN. A barcode cannot tell a recycler which battery is in their hand.
See what a GTIN is and product identifiers.
A passport holds structured data, and that data sits somewhere else
The Ecodesign for Sustainable Products Regulation (ESPR) is the EU law that creates the passport. It has been in force since 18 July 2024.
The code on the product is still only a code, and the passport is the data at the other end of it. See what a digital product passport is.
Three properties separate that data from a web page.
- A machine reads it field by field, without a person to interpret it.
- Each group of readers sees a different set of fields.
- The data stays available after the company stops trading.
ESPR Article 10(c) requires the economic operator responsible for the passport's creation, or a digital product passport service provider, to store the data. Recital 41 requires a decentralised data system. The EU does not hold your product data.
A passport is a condition of market access, and a barcode is not
| Question | A retail barcode | A digital product passport |
|---|---|---|
| What it holds | One identifier | Structured data about the product |
| What it names | The product model | A model, a batch or one item |
| Where the data sits | In each company's own system | With the operator or its service provider |
| Who reads it | A scanner at the till | The public, authorities and other readers, as the product rule allows |
| What EU law says | No passport rule | ESPR Article 9(1) makes a passport a condition of market access |
Article 9(1) creates no duty for a specific product by itself. The duty arrives through a product group rule, called a delegated act. See how a passport works and who can see what.
The law names ISO/IEC 15459, and neither GS1 nor QR
Some suppliers claim more than the law says. Read this part carefully.
ESPR 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 ISO/IEC 15459-6. The number under your retail barcode is named in the regulation.
Article 10(1)(c) makes this 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 any of these terms:
- GS1
- Digital Link
- IEC 61406
- the digital object identifier (DOI)
- ISO/IEC 18004, which is the QR code standard
So ESPR does not require a GS1 Digital Link web address, and it does not name the QR code. A supplier who tells you that the law demands either one is wrong about the law. Your EU customer can still ask for either one as a condition of sale. See GS1 Digital Link and identifier schemes.
Batteries show the difference inside one regulation
Regulation (EU) 2023/1542, the battery regulation, is in force. It treats a code and a passport as two separate duties.
| Article | The duty | Which batteries |
|---|---|---|
| 13(6) | A QR code under Annex VI Part C, which leads to other information | Every battery |
| 77(1) | A battery passport, which applies from 18 February 2027 | Three categories only |
Article 77(1) names exactly 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
A light means of transport battery carries no size threshold. A small e-bike battery needs a passport, and so does a large one.
Article 77(3) requires a unique identifier for each battery. A GTIN names the model, so a model number alone cannot carry a battery passport. See batteries.
Identification comes first, and the passport adds data to it
Identification comes first. A passport needs an identifier, and it adds data to that identifier.
Keep the work you already do:
- Allocate each GTIN cleanly, and keep one number for one product model.
- Keep the same product data in every system that holds it.
- Name the person who owns each field.
Add these parts when a rule reaches your product group:
- an identifier at the level the rule sets, if model, batch or item
- structured data that a machine can read
- a rule that states which reader sees which field
- a place for the data to live after your company stops trading
The code on the product is the smallest part of that list. See data carriers and what is not a digital product passport.
The 2027 barcode target is not a passport deadline
Warning: the GS1 barcode target and the battery passport date are both in 2027, and they mean different things.
GS1 has an industry target for retail point-of-sale systems to read both linear barcodes and two-dimensional barcodes by the end of 2027. A QR code is one type of two-dimensional barcode. The target is an industry capability, and it is not a law. GS1 states that linear barcodes continue in use during the change.
The battery passport date is law. It applies from 18 February 2027, and it reaches the three categories in the table above.
No ESPR passport duty applies to any product group today. As at August 2026 the European Commission has adopted no delegated act for any group. Read how to read the timeline before you accept a date from a supplier.
Your EU importer holds the duty, and only you hold the data
The passport duty falls on the operator that places the product on the EU market. For a New Zealand company with no EU establishment, that operator is the EU importer.
Your barcode, your identifiers and your product data still come from you. Your importer cannot supply data that only you hold. See what this means for New Zealand exporters.