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

A standard for the QR code, not an obligation in itself

GS1 Digital Link is a technical way to build a QR code so that it does two things at the same time: uniquely identify a product (like a GTIN that already appears on packaging) and provide a link to a web page with information about that product. For the digital product passport, this is attractive because the ESPR requires a data carrier that refers to the correct product information and is uniquely linked to a product or product group. GS1 Digital Link is an existing, globally used standard that can meet those two needs, but the ESPR itself does not prescribe a specific technical standard in the text currently available. Which standard will ultimately be mandatory for the data carrier and identification code will be determined by delegated or implementing acts that the European Commission establishes per product group.

For whom this is relevant and for whom it is not

This question is particularly relevant for parties that will themselves create a QR code or other data carrier and attach it to a product: manufacturers, importers, and parties that compile a passport on their behalf. For a steel trader or metal processor that purchases semi-finished products and receives the passport from the supplier or from a service like this one, the technical structure of the QR code is not a practical choice of their own — the code is already created and linked to the product. For them, what matters most is that the code works and leads to the correct, up-to-date data, not which technical standard underlies it. GS1 Digital Link is not about the content of the passport (which data must be included) and not about who may compile the passport; those are governed by other parts of the ESPR and the delegated acts yet to be published per product group.

No fixed date yet, but a timeline

There is no yet established date on which a specific technical standard for the data carrier, such as GS1 Digital Link, becomes mandatory for iron and steel. The ESPR provides for a work plan for the period 2025-2030, in which delegated acts are prepared and adopted per product group. For iron and steel, the first delegated act is expected around 2026, with obligations expected to follow approximately eighteen months later — hence the estimate that the passport for this product group will become a reality around 2028. This date is not yet fixed. Until the delegated act for iron and steel has been published and the associated technical specifications are known, there is also no definitive answer to the question of which standard for the data carrier will be prescribed exactly. As soon as that becomes known, it will be added here.

How this works in practice

For those preparing now, there is no need to wait for everything, but the question about GS1 Digital Link is best considered in the right sequence. First: is it about creating a data carrier yourself, or about receiving a passport that has been compiled by someone else? In the latter case, the technical standard of the QR code is not a point of focus for you. If you are going to create or have a data carrier created yourself, you can already familiarise yourself with GS1 Digital Link as an existing standard, because it is already widely used in other sectors with product identification and has a good chance of also playing a role in the product passport. A direct link to existing GS1 identification codes (such as a GTIN, if one is already used for the product) can make that transition easier later, without committing to anything that is mandatory now. Moreover, it is practical to follow when the delegated act for iron and steel is published, since the technical requirements for the data carrier will be specified in detail there.

The basis: Articles 11 and 12 ESPR

That there must be a data carrier which technically meets certain requirements and which uniquely identifies the product follows from Article 11 and Article 12 of the ESPR (Regulation (EU) 2024/1781). Article 11 governs the technical design and operation of the digital product passport, including the way in which the data carrier and the underlying data must function. Article 12 governs the unique identification code that a product or a group of products must receive. Both articles leave the precise technical implementation — including the choice of a standard such as GS1 Digital Link — to later delegated or implementing acts, which are established per product group.

If you want to do something at this moment, it is best to determine whether your own role is that of a passport compiler or that of a recipient, and on that basis determine whether the technical structure of the QR code is a point of your own attention. For the current, definitive technical requirements for the data carrier for iron and steel, the publication of the delegated act remains the moment to look forward to; as soon as it is available, this page will be supplemented with it.

What this is based on

The regulation itself can be found on EUR-Lex. We provide references for each statement; you do not have to take our word for it.

What you must concretely do

GS1 Digital Link is a way to construct a barcode or QR code so that a single scan can work in multiple ways. The same code that appears on the pallet, the coil or the rod can simultaneously refer to the product passport, to logistical information and to other data about that specific product. The code is structured as a web address (a URL) with fixed elements such as a GTIN (the article number according to the GS1 system) and possibly a batch or serial number. A scanner or mobile phone that reads the code automatically arrives at the right place — at a web page, not at a file that must first be downloaded.

For the digital product passport, this is relevant because the ESPR specifies in Article 11 that the passport must be accessible via a data carrier, and that the carrier is linked to a unique product identification code as referred to in Article 12. GS1 Digital Link is not the only way to technically implement this, but it is an existing, internationally used standard that solves exactly that problem: one code, one button press, and the correct information on screen. For steel traders and metal processors who already work with GS1 barcodes for logistics and invoicing, that is a practical connection to something that is often already there.

What is expected of you

A readable, unique code on or attached to the product

Article 12 of the ESPR calls for a unique product identification code per product. For a company with 10 to 100 employees, this means in practice that there must be a code that does not coincidentally also belong to another product, and that uniquely refers to one passport. Whether that code is constructed according to GS1 Digital Link or in another way is determined in later delegated acts per product group. How that code is actually placed on the steel itself — as a sticker, engraving, or via the packaging — depends on the product and the format, something that will be further developed in How does the QR code for the product passport get on my steel?

One code that leads to one passport, not to a collection of loose documents

The purpose of Article 11 is that a scan leads directly to the correct, up-to-date information. That is more than just "sticking on a QR code": the underlying structure must be arranged so that the code continues to work, even if a new batch of the same product arrives or if data is updated. For companies that themselves assemble semi-finished products from multiple raw materials, the question also arises how this relates to situations in which multiple product passports for a product are necessary.

Consistency between the identification code and registration of batches

In steel and metal, registration is often not per piece but per batch or coil. GS1 Digital Link can include a batch or lot number in the code, but this only works if it is clear within the company when something counts as one batch and when it does not. That is an organisational question that is separate from the technique, and which will be discussed further at Do I register steel per batch or per piece?

Connection to your own systems

An identification code does not exist in isolation: it must correspond to a line in the ERP system, inventory management or production administration. For companies considering automating this rather than manually generating codes, the question whether the product passport can be linked to your own system is one of the first that arises as soon as the technique goes beyond a loose sticker.

Where things go wrong in practice

A few situations come back with companies that work with GS1 Digital Link or are considering doing so:

The code is copied to a next batch. To save time, the same QR code is reprinted for a new batch of steel, with the result that two different batches refer to the same passport. That undermines precisely the purpose of the unique product identification code from Article 12.

GS1 Digital Link is confused with a regular GS1 barcode. Existing logistics barcodes are often not suitable to serve as passport access without modification, because they are not structured as web addresses. Those who assume that the barcode already on the packaging automatically complies often only discover this during implementation.

The code exists, but the passport behind it no longer does. If a link points to a page that has been removed or is no longer maintained, the code is meaningless. This directly touches on the question how long a product passport must remain available and who is responsible for that.

No account is taken of small components. For small steel products there is literally insufficient surface area for a readable code, even not in Digital Link format. That is a technical problem that is addressed separately in how to get a QR code on a small piece of steel.

It is assumed that a scan always requires internet. Some applications in the chain, for example on a construction site or in a warehouse without coverage, require consideration of whether and how information can be consulted without a connection — something that comes up in the question whether the passport must also be available offline.

What you can document

  • An overview of which products already have a GS1 barcode, and whether that code is structured according to the Digital Link format or according to an older GS1 format.
  • An internal agreement on the moment when a new identification code is created: per production run, per batch, or per unit sold.
  • Documentation on which system manages the link between code and passport data, and who is responsible for changes to it.
  • An established procedure for testing whether a scanned code actually leads to the correct, up-to-date page — especially when the passport is updated.
  • Agreements with suppliers or importers about who assigns the identification code, particularly when a semi-finished product is further processed by multiple parties.
  • A note on the chosen file structure and organisation of the underlying data, in line with the question in what format the data for the product passport must be supplied.

This is not legal advice. This page provides general information about the legislation that this platform deals with. We do not know 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 not right? Let us know — corrections are given priority.