How it works
What a product identifier is, and what the law requires
A unique product identifier names one product and nothing else. EU law names the ISO/IEC 15459 series, and no vendor scheme.
A unique product identifier is the code that separates one item from every other item you sell. The Ecodesign for Sustainable Products Regulation (ESPR) names the ISO/IEC 15459 series for that code, as an interim rule under Article 10(1)(c). No vendor scheme appears in the text.
A digital product passport needs an identifier first, because the passport data attaches to that code.
Two mistakes cost money here. The first is to buy an identifier scheme because a supplier says European law demands it. The second is to number each single item before a rule asks for it. An identifier can name a model, a batch or one single item. Item level work reaches your production line, and model level work stops at your database. If you build the wrong level, you build it again.
The identifier names the product, and the data sits somewhere else
A digital product passport is structured data about one product. The code on the product holds the identifier, and not the data. The data sits with the company that places the product on the European Union (EU) market. It can also sit with a service provider that the company pays.
So the identifier does two jobs. It names the product, and it lets a machine find the right record. See how a passport works.
The thing you print is the data carrier. A QR code is one data carrier, and a radio tag is another. See data carriers.
ESPR names the ISO/IEC 15459 series
ESPR is Regulation (EU) 2024/1781. It entered into force on 18 July 2024. 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.
Read the words "where relevant for the products concerned", because the rule is not absolute. Each product group gets its own rule later, and that rule decides what applies.
Annex III(c) names the Global Trade Item Number (GTIN) under ISO/IEC 15459-6. A GTIN is the number under the retail barcode on a merino jumper. See what a GTIN is.
Article 10(1)(c) makes that an interim rule
Article 10(1)(c) allows those standards, "or equivalent European or international standards until the references of harmonised standards are published".
So the ISO/IEC rule runs until the references of the harmonised standards appear. The European Commission cited EN 18219, the standard for unique identifiers, in July 2026. This site has not read that text, because it is paywalled.
A citation does not make a standard mandatory. EN 18219 stays voluntary, and a product built to it gets a presumption of conformity. See EN 18219.
ESPR names no vendor scheme
A search of the full regulation returns no hit for GS1, for Digital Link, for IEC 61406 or for the digital object identifier (DOI). It returns no hit for ISO/IEC 18004, the QR code standard, either.
A supplier may tell you that European law demands one particular scheme in your code. Ask that supplier to name the article. Your EU customer can still ask for a scheme as a condition of sale, and that is a commercial request. See GS1 Digital Link.
The level decides the cost: a model, a batch or one item
Three levels are possible, and the words are not interchangeable.
| Level | What one identifier names | Example |
|---|---|---|
| Model | Every unit of one product | Every jumper of one style, colour and size |
| Batch | One production run | Every jumper knitted from one dye lot |
| Item | One physical unit | One e-bike battery with its own serial number |
A GTIN names the model. Two identical e-bike batteries from one production run carry the same GTIN. That number cannot tell a recycler which battery is in their hand.
GS1 states that its standards already put extra data in a code, such as a batch number or a serial number. GS1 is an industry body, and it is not a regulator. Cite it for what a standard does, and not for what the law requires.
A battery passport names one battery
Regulation (EU) 2023/1542, the battery regulation, is in force. Its passport duty starts on 18 February 2027. Article 77(1) names the batteries it covers. There are 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
Warning: an LMT battery carries no size threshold. A Commission news item of 20 July 2026 uses the loose phrase "large batteries" for this duty. Do not read that phrase as an exemption for an e-bike battery.
The Commission web page on digital product passports writes "certain types of batteries, including". Do not read that open list as an exemption either.
Article 77(3) requires a unique identifier for each battery. So the battery passport sits at item level. One passport for a model or for a batch does not meet that article. See batteries.
The registry act adds three rules about the level
Commission Implementing Regulation (EU) 2026/1778 runs the EU registry. It has been in force since 6 August 2026. Article 8 decides the level at which a passport goes into that registry.
Warning: this act sets no date for any product. Article 8(1) ties an ecodesign registration to a delegated act. This site searched the Official Journal and the Commission product group pages, and no adopted act came back.
| Rule | What it says |
|---|---|
| Article 8(3) | Where two Union rules ask for different levels, the passport goes in at the most detailed of them |
| Article 8(4) | An item level passport must also carry the batch identifier and the model identifier |
| Article 8(5) | A batch level passport must also carry the model identifier |
Read Article 8(4) against the battery duty. An item level battery passport does not replace your model number, but carries that number as well.
One condition limits the last two rules. Article 8(4) applies where a batch and a model design exist, and Article 8(5) applies where a model design exists.
Recital 14 of the same act covers a product that has no batch and no model. A product that is unique by nature needs neither identifier, and the recital names handmade goods as the example. So the economic operator decides if a batch and a model design exist.
No ESPR product group has a stated level
Warning: do not copy the battery answer onto your own product.
The Commission has adopted no delegated act under ESPR for any product group, as at 14 August 2026. A delegated act sets the passport requirements for its product group. Until one exists, no level is stated for a jumper, a chair or a tyre.
Industry says the same thing. GS1 runs an apparel working group on the passport. That group waits for the delegated act to state which level applies. GS1 opened the group before the act, because the data work takes years.
So a supplier who tells you today that a textile passport needs a serial number for each garment is guessing. See how to read the timeline.
Per model is a data problem, and per item is a production line problem
At model level you hold one record for each product model. The work is office work. Clean up your product data. Name the owner of each field. Keep one number for one model.
At item level every physical unit needs its own number. You create that number at the point of manufacture. You print it on the unit, and you record it. The number must stay with the unit. The work reaches the factory, the label and the systems that track a unit after it leaves you.
Batch level sits between the two. You number a production run, so the line changes the code less frequently than at item level.
OwlQR, a New Zealand company that publishes this site, builds product identity software. Ask any provider which of the three levels its system supports before you buy.
No published pilot gives a cost figure for any of the three levels. This site will not give you one either. See what a passport costs.
What this site searched, and what came back, is listed in what this site does not know.
The registry stores identifiers, and the EU operator uploads them
Article 13(1) required the Commission to set up a registry that stores at least the unique identifiers. The registry is operational. Two dates appear in published material, and both of them are correct.
| Date | What it is | Status |
|---|---|---|
| 19 July 2026 | The deadline written in Article 13(1) | Statutory |
| 20 July 2026 | The launch, with a test environment | Operational |
Article 13(4) puts the upload on the economic operator that places the product on the market. No operator must upload yet, because no delegated act applies.
Warning: the registration identifier is not the product identifier. The registry gives you the first one. You create the second one, and you put it in the data carrier. See the EU registry.
The registry implementing act says what the registry keeps. Article 8(9) names the unique identifiers, the commodity code, a reference to a passport service provider, and information about the registrant. Article 8(8) returns one unique registration identifier, and that identifier is persistent.
A product identifier is not the only identifier in a passport
Commentary describes two more kinds of identifier: one for the economic operator, and one for the facility. This site has not read EN 18219, so it states nothing about what that standard requires of either one. It also publishes no count of the schemes that the standard permits. See operator identifiers and identifier schemes: what is verified.
An e-bike battery needs its own number, and a jumper does not
- If you export an e-bike battery, give each battery its own number.
- If you export a jumper or a chair, keep your model numbers clean and correct.
- Do not buy item level numbering for a product group with no rule.
- Ask your EU importer which identifier they need, and who creates it.
Your importer usually places the product on the EU market, so your importer usually holds the duty. A white paper from three EU-funded projects says a non-EU manufacturer stays a duty-holder as well. That paper is not the legal text.
Your importer cannot upload a number that you never sent. See what a non-EU exporter must supply.
If you export food or drink, no ESPR passport reaches that product.