How do I give each product a unique identification code?

Each product receives its own code, linked to the passport

Under the ESPR, every product falling within the scope of a delegated act receives a unique identification code. This code is the identifier by which a product, a product model or a batch of products can be traced back to the corresponding digital product passport. Article 12 of Regulation (EU) 2024/1781 (ESPR) stipulates that this code is part of the passport and that it works in conjunction with the data carrier — usually a QR code — which is affixed to or accompanying the product. The identification code is therefore not simply an internal article number of the manufacturer: it is the element by which a competent authority, a trader or a consumer can retrieve the passport of that specific product.

Who this applies to, and what it does not

This obligation applies to product categories for which a delegated act under the ESPR has been adopted and is in force. For electrical and electronic equipment, this is regulated per subcategory: washing machines, smartphones, servers and other groups each receive their own delegated act, with specific requirements for, among other things, the identification code. As long as no delegated act has been published and is in force for a specific subcategory, the obligation for a unique identification code does not yet apply to that category.

It is also important at what level the code is assigned. Article 12 allows for identification at the level of the product model, the batch, or the individual item — which level applies is determined per product category in the delegated act. This means that "a unique code per product" in practice may result in a code per model that is the same for thousands of identical specimens, or conversely in a code that differs for each physical item. This distinction is decisive for the design of a registration system, and it only becomes clear once the delegated act for the relevant subcategory is in place.

When this enters into force remains uncertain

There is no fixed date yet for when the obligation for a unique identification code for electrical and electronic equipment enters into force. According to the ESPR work programme 2025-2030, delegated acts are being prepared per subcategory, with the expectation that the first acts will be published from 2027 onwards. Until a delegated act for a specific subcategory has been adopted and entered into force, no obligations apply to that category on the basis of Article 12. As soon as an act for electrical and electronic equipment is published, the date and its content will be processed here.

How this is tackled in practice

Those preparing for this should start by inventorying their own product structure: which products are identical in terms of model, where variants exist, and at which level (model, batch, item) identification would be logical given the way the company manufactures and distributes. This is useful preparation, even though the definitive level is laid down in the delegated act still to be published.

A second step is to consider the technical side: a unique identification code must be machine-readable and compatible with the data carrier prescribed by Article 11 of the ESPR. This means that the code and the QR code or similar carrier must be aligned with each other, and the code must continue to point to the correct passport throughout the entire period that the passport must be available.

A third point is management over time. An identification code attached to a product must remain traceable even years later — particularly relevant for electrical and electronic equipment, where repair, resale and recycling often occur years after the initial sale. Those setting up a product coding and registration system now would be well advised to account for a long lifespan of that link, and for the possibility that the code must work with an external platform that hosts the passport.

Finally, it is worthwhile to follow the specialist literature and the publication of delegated acts for your own product subcategory: only in these will it be determined at which level (model, batch or item) the identification code must be assigned and what technical specifications apply.

Established in Article 12 and Article 11 of the ESPR

The obligation to have a unique identification code follows from Article 12 of Regulation (EU) 2024/1781 (ESPR). Article 11 of the same regulation describes the technical design and functioning of the digital product passport in a broader sense, including the data carrier with which the identification code is linked to the passport. Both articles work together: Article 12 determines what is uniquely identified, Article 11 determines how that identification is technically disclosed. The precise implementation per product category — which identification level, which format — is determined in the delegated acts that the European Commission publishes per product subcategory.

If you want to start now, it is best to begin by mapping your own product structure and exploring the technical setup of a coding and registration system, so that you can act quickly when the delegated act for your own product subcategory is published. Elektropas follows the publication of these acts and updates the information on this page as soon as a date and content become known.

What this is based on

The regulation itself is on EUR-Lex. We provide references per statement; you do not have to take our word for it.

What you must concretely do

What is expected of you

Article 12 of the ESPR (Regulation (EU) 2024/1781) stipulates that each product for which a digital product passport becomes mandatory shall receive a unique identification code. This code is the key by which a product, and the passport that belongs to it, can be uniquely traced — by a competent authority, a recycler, a trading partner or the consumer who scans the QR code. What this means in practice breaks down into a few separate obligations.

Each product receives its own code, not a model code

The identification code must identify the individual product, not merely the model or product line. For a manufacturer of consumer electronics or ICT equipment, this means that a production batch of a thousand identical washing machines cannot be satisfied with a single code: each unit receives its own unique code, even if the technical specifications are identical. For a company of 10 to 100 employees, this is often the first hurdle, because existing article numbers are typically set up at model level and not at serial number level.

The code must align with a recognized coding system

Article 12 allows for different technical systems, provided the code complies with internationally recognised standards for unique identification. In practice, this prompts many importers and manufacturers to connect to an existing system rather than build something of their own. A commonly used route is via GS1, and on the question What is GS1 Digital Link and do I need it for the digital product passport? it is explained how that standard relates to the identification code from Article 12.

The code must be linkable to the passport and to the QR code on the product

The identification code is not separate from the passport or from the data carrier on the product. Article 11 of the ESPR describes the technical requirements for the digital product passport itself, and the identification code is the element that links passport, product and data carrier to one another. Those who wonder what that link looks like in practice will find on How does the QR code for the digital product passport get on my electronics? an explanation of that technical process.

The code must remain unique, even after modifications

When a product passport is updated — for example because a component has been replaced or a repair has been carried out — the underlying identification code generally does not change. The code follows the product, even if the contents of the passport change. This places requirements on the way a company structures its internal systems: the code must be assigned once and then not change again, even for internal administrative adjustments.

The code must be accessible via the European register

In addition to the link with the passport itself, there is also a registration obligation related to the identification code. On What is the register of digital product passports and what do I need to enter in it? it is described which data are entered there and how the identification code plays a role in it as a search key.

Where things go wrong in practice

A number of situations regularly come up in practice at companies that are just beginning to set up their identification system.

An importer uses the existing EAN number of a product line as a "unique" code, without realising that this number is identical for thousands of units of the same model. Once a competent authority or customer wants to trace an individual product, the code proves unable to distinguish between units.

A manufacturer assigns the identification code at the moment of shipment, but the internal ERP system overwrites the number when the product is returned or a warranty claim is made. The result is that the passport and the physical product no longer belong together. Those who recognise this risk will find on Can I link the digital product passport to my ERP or inventory system? a description of how that link can be arranged so that the code remains stable.

A company works with multiple levels of packaging — a box with loose devices that go into a larger transport box — and inadvertently assigns only one identification code to the outermost packaging. When scanning on the shop floor, it is then no longer possible to determine which individual device belongs to which product passport. How this works for layered packaging is explained on how does the product passport work for a box with multiple devices in it.

An ICT equipment importer thinks that the identification code is only relevant as long as the product is in stock, and removes the link from the system as soon as the product is sold. Because the product passport must remain available for a number of years, this is a risk: without the code, the product passport can no longer be found from the product, even though the product passport itself is still online.

A company uses different coding systems side by side — one warehouse works with internal batch numbers, the other with an externally assigned GS1 code — without a central place where it is recorded which code belongs to which product passport. This leads to duplicate or missing links as soon as data is exchanged between systems.

What you can document

An overview of the selected coding system (for example GS1 or an in-house system) and the reason why this system was chosen.
An internal procedure describing at what point in the production process the identification code is assigned, and by whom.
A linking table or system field in which the identification code, the product passport and the QR code on the product are linked to each other.
Agreements with suppliers or subcontractors about who assigns the identification code when components or modules are produced separately, relevant for My product needs multiple digital product passports — how does that work together?
A procedure for what happens to the identification code in the event of a return, repair or replacement of a component.
A documented procedure for submitting the identification code to the European register, including who within the company is responsible for this.
Documentation of the file format in which the identification code and the associated product passport data are submitted, see also in what format must I provide the product passport data

This is not legal advice. This page provides general information about the regulations that this platform covers. We are not familiar with your situation. If you are in doubt about your own case, consult a lawyer or the competent supervisory authority.

Written with AI based on the sources above, checked by a human on 2026-08-22. Is something incorrect? Let us know — corrections take priority.