The short answer
The unique identification code is the characteristic by which one specific product, or one specific batch of a product, is distinguished from all others. That code is not separate from the digital product passport; rather, it is the key to it: it is embedded in the QR code on the product and refers to precisely that one file, not to a general product page or a type designation.
With iron and steel, this distinction is less self-evident than it sounds. A hot-rolled steel coil and a bar from the same production line may look identical to the eye, while the composition, rolling date, or origin of the raw material differs. The identification code ensures that a user later — at a trader, a processor, or a supervisory authority — opens the correct file, and not that of a comparable but different product.
What the code connects
The code acts as a link between three things: the physical product, the data that the manufacturer or importer has provided, and the place where that data remains accessible for ten years. Without that link, a passport is nothing more than a loose document; with the code, every reader of the QR data carrier knows exactly which product lies before them. how that link works in practice shows how the data flows from submission to QR code.
The regulation itself describes the principle — a product must be traceable to its own file — but leaves the precise technical form of the code to delegated acts per product group. For iron and steel, that elaboration does not yet exist. What is established is the objective; what still must come is the exact structure.
Who assigns the code
Assigning the code is typically the task of the party that also compiles the rest of the passport: the manufacturer, or in the case of imports, the importer designated as responsible in the regulation. This party determines not only what is in the file, but also to which product or batch that file is attached. Who in your own chain precisely fulfils that role depends on where the steel was produced and through which parties it reaches you; the knowledge base in which this has been worked out for each situation goes into greater detail than is appropriate here.
What this means for your daily administration
For a trader or processor, the most important consequence is practical: the identification code becomes the connection point by which purchase orders, inspection certificates, and internal records can be linked to one another. If you already work with batch numbers or rolling certificates, you will partially recognize that habit — the difference is that the code will be digitally accessible via one fixed QR data carrier, rather than on paper with the shipment.
Whether this is already relevant for your products and your role in the chain varies depending on the situation. In a few questions you can see roughly where you stand, without immediately needing an account for that.
What is not yet established
The exact structure of the identification code — length, format, or whether it aligns with existing international numbering systems, for example — is part of the delegated acts announced in the ESPR work plan for 2025-2030. The first of these is expected in 2026, with obligations taking effect some time after that. As soon as a text for iron and steel is published, that is the moment when the details of the code are established; until then, caution with definitive statements is in order.
For your own situation, and for questions that go beyond this single concept, the official text on EUR-Lex or a lawyer is the appropriate point of contact. Those who first want to see which other concepts and obligations are related will find on the page with frequently asked questions an overview without legal jargon.
Would you like to get an impression of what this could mean for your own products without immediately creating a file for it? The free quick-scan provides initial direction in just a few minutes, and the knowledge base remains available afterward as a reference work.