What is GS1 Digital Link and do I need it for the digital product passport?

What you must concretely do

What is expected of you

GS1 Digital Link is not a legal term from the ESVPR, but a technical standard: a way of structuring a QR code or barcode so that a single scan both points to the unique identification code of a product and to the location where the product passport data is stored. The ESVPR itself does not prescribe this format mandatorily, but Article 11 of the ESVPR (Regulation (EU) 2024/1781) determines that the product passport must be accessible via a data carrier and that the technical design must comply with the requirements to be established per delegated act. Article 12 of the ESVPR (Regulation (EU) 2024/1781) concerns the unique identification code itself: the product must be identifiable in an unambiguous manner, linked to the data from the passport.

For a company with 10 to 100 employees, this breaks down into a few practical expectations.

A data carrier that can be read on the product

The QR code (or a comparable carrier) must be present on or with the product and remain readable. How that code exactly ends up on the product, and what options exist for that, is described on the page about how the QR code for the product passport gets onto electronics. GS1 Digital Link is one way to technically structure that code, but the obligation itself concerns the presence and readability of the carrier, not one specific format.

A unique identification code per product

Article 12 of the ESVPR (Regulation (EU) 2024/1781) calls for an identification code that unambiguously distinguishes the product. GS1 Digital Link is built around existing GS1 identification codes (such as GTIN), processed in a URL structure. Anyone already working with GS1 codes for logistics or retail may be able to reuse that structure for the passport. Those who do not yet do so will first need to determine how a unique code per product is assigned — that process is explained on the page about how each product receives a unique identification code.

Linking code to passport data

The code on the product must lead to the actual data. With GS1 Digital Link, this happens through the URL structure itself: the code already contains the reference to where the data is located. For companies that already manage their product data in an ERP or inventory system, it is relevant how that link between system and passport is practically established — this is addressed on the page about linking the passport to your own system.

Complying with the format prescribed by the delegated act

Which technical format ultimately becomes mandatory (or whether GS1 Digital Link is mentioned as the only option, as one of several, or as a non-mandatory option) follows from the delegated act per product category. This does not yet exist for electronics. Until then, GS1 Digital Link is a standard that aligns with what is already common in the market, not an obligation that follows from the ESVPR text itself.

Where things go wrong in practice

GS1 Digital Link is confused with a legal obligation. Because the standard is frequently mentioned in the context of product passports, the impression arises that GS1 Digital Link is mandatory. The ESVPR itself does not mention this format; it is a technical implementation that aligns with Article 11 and Article 12 of the ESVPR (Regulation (EU) 2024/1781), but the obligation lies in the objectives (readable carrier, unique code), not in the specific format.

Companies build a QR code without taking into account existing GS1 structures. If you already use GTINs for logistics and then set up a completely separate numbering system for the passport, you make it unnecessarily complex for yourself. This is particularly relevant for companies that have had their inventory system and product passport developed separately.

It is assumed that one GS1 Digital Link code is sufficient for packaging with multiple devices inside. With boxes containing multiple units, or with sets, it is not self-evident at which level (individual device, packaging unit, box) the code should be carried. This touches on the question of the product passport works with a box containing multiple devices.

The link to the passport is set up technically sound, but not future-proof. A GS1 Digital Link URL pointing to a temporary hosting environment risks the link no longer working after a system change. This raises the question how long a product passport must remain available and what hosting requirements apply to this.

Companies wait to decide until the delegated act is in place, and only then start with their data structure. Because GS1 Digital Link connects to existing product codes, the preparation (which code belongs to which product, in which system that data is stored) can be separated from the question of what exact format will eventually be mandatory.

What you can document

• An overview of which product codes are already in use (GTIN or other GS1 codes) and whether they are suitable as a basis for a unique identification code per product.
• A description of how the link between product code and passport data runs technically, including which system is the source of truth for the data.
• Agreements with the hosting provider about the durability of the URL structure, especially if a GS1 Digital Link structure is chosen — relevant in connection with the question where the hosting of the product passport must comply with.
• A documented choice on the level at which encoding takes place (individual device, packaging, box), especially for products sold in sets or multipacks.
• Documentation of the file format in which the underlying passport data is submitted, which connects to the question in which format the product passport data must be submitted.
• A note on the source and version number of the GS1 standard used, so that if the standard is changed, it is clear which version was applied at that time.