How do I give each product a unique identification code?

What you must concretely do

What is expected of you

Article 12 of the ESPR (Regulation (EU) 2024/1781) requires a unique identification code per product to which the digital product passport applies. This code is the key with which the passport can be retrieved and linked to the correct physical product. What this concretely means is broken down into a few separate requirements.

Make each product identifiable with its own code

The code must unambiguously distinguish the product from other products, including from other copies of the same model. For a company with 10 to 100 employees, this usually means that the existing internal article numbering is not sufficient as is: it is often set up per model or per order, not per physical unit or per batch. A system must be developed that operates at the level at which the passport is issued. Whether this happens per unit or per batch depends on the product and is further elaborated in the topic Do I register steel per batch or per piece?.

Link the code to the correct passport

The identification code must refer to one specific passport, and that passport must in turn display the correct, up-to-date data. This directly touches on Article 11 of the ESPR, which sets requirements for the technical design and operation of the passport itself. In practice, this requires a seamless link between the code, the data carrier (usually a QR code) and the place where the passport data actually resides. Companies that already work with an ERP or inventory system are well advised to examine how this link is technically established; see Can I link the product passport to my ERP or inventory system?.

Ensure that the code remains unique, even after sale or transfer

An identification code that is unique at the time of issue must remain so if the product changes owner, is processed or passes through an intermediary. For metal processors and steel traders who purchase, process and resell semi-finished products, this means that the origin code from the original manufacturer must not be lost in their own process. When a product is processed in multiple steps and new product units are created in the meantime, the question may arise whether there is one passport or multiple linked passports; this topic is covered in My product needs multiple product passports — how does that work together?.

Register the code where required

In addition to the link to the passport itself, there is the question of whether and how the identification code must also be known at a central level. This touches on the broader system of registration surrounding the passport, more information about which can be found at What is the register of digital product passports and what must I enter in it?.

Where things go wrong in practice

The internal article number is reused as the product code. Many companies already have a numbering system for inventory management or invoicing. This system is usually not designed to be unique at the level that the passport requires, and certainly not to be recognizable outside the company's own administration. Without adjustment, there is a risk that two different physical products nonetheless receive the same code, or that the code means nothing outside the company's own records.

The code is managed separately from the passport. In some cases, the identification code is created by one department or system, while the passport itself is compiled and hosted by another party. If the two do not align well, a passport exists that cannot be found via the code on the product.

When steel is processed, the product changes, but not the code. A sheet or profile that is sawed, coated or otherwise processed may in practice become a different product than the original semi-finished product. When the old identification code is simply carried over while the properties of the product have changed, the code no longer matches what data actually belongs to the product.

The code is not carried forward for small or loose parts. For smaller steel items, there is not always physical space to apply a complete code or QR code, which puts the link between the physical product and the digital code under pressure. This is particularly relevant for smaller components; see how do I get a QR code on a very small piece of steel.

No account is taken of the lifespan of the code. An identification code that must continue to refer to an existing product passport for ten years or longer requires a management system that lasts longer than the current ERP package or the current hosting service provider. If this is not documented, there is a risk that the code is on the product at some point, but no longer refers to anything anywhere.

What you can document

• The system by which identification codes are assigned: per item, per batch, or per model, with the reason for that choice.
• The link between the internal article number (if used) and the external identification code of the product passport, so that both systems remain traceable to each other.
• Agreements with the party that compiles and hosts the product passport regarding who assigns the identification code and who is responsible for keeping the link up to date.
• A procedure for the moment when a product is processed, split or combined, with documentation of which identification code applies thereafter.
• The manner in which the code is technically applied to the product or packaging, including alternative solutions for small components.
• An overview of which data format is supplied when compiling the product passport, more information on which can be found at in what format must I submit the data for the product passport.

For each of these points it holds that documentation in advance entails less work than reconstruction afterwards, especially when a product must still be identifiable years after the product passport has been issued.