Reviewed as of 2026-07-22 · Educational · Not legal advice
Unique product identifier
Under ESPR, a “unique product identifier” is a unique string of characters for the identification of a product that also enables a web link to the digital product passport.
A digital product passport must be connected through a data carrier to a persistent unique product identifier. The data in the passport must be accurate, complete, and up to date when the applicable rules require a passport.
Data carrier placement
ESPR defines a data carrier as a linear barcode symbol, a two-dimensional symbol, or another automatic identification data capture medium that can be read by a device.
The data carrier must be physically present on the product, its packaging, or on documentation accompanying the product, as specified in the applicable delegated act. The Commission’s overview likewise describes a digital data carrier (such as a QR code) linking the physical product to its DPP.
Model, batch, or item — set per product group
Delegated acts under ESPR specify, among other things, which data carriers to use, how they are laid out and positioned, and whether the passport is established at model, batch, or item level. That means serialisation at item level is not a universal legal rule for every product today — your product group’s act (when adopted) sets the level.
Interoperability and standards
The data carrier and unique product identifier must comply with standards referred to in ESPR (Annex III) or equivalent European or international standards until harmonised standards are published in the Official Journal. Passport data should be based on open standards, machine-readable where appropriate, and transferable through an open interoperable network without vendor lock-in.
Ops readiness (not a legal mandate list)
While you wait for (or implement) product-specific acts, product-ops teams typically prepare a durable ID scheme, a machine-readable carrier that can survive the product’s life, and an updateable hosted record behind the carrier. Those are readiness practices — confirm the exact carrier technology and identification level in your applicable act.
Gaps this maps to in the readiness check
No stable unique product identifier
Pick an identifier standard (e.g. GTIN now, serial/item IDs for units) and assign ownership in ops/PLM.
Identity stops at SKU or batch
Plan serialization at pack-out even if your first category act starts at model level.
No on-product data carrier
Choose QR, Data Matrix, and/or NFC placement that survives the product’s life; avoid carton-only as the sole link.
Carrier won’t survive product life
Move the carrier onto a durable label or embedded tag and document reprint/reassign process.
No updateable hosted record
Host product data at a stable URL with access control — avoid season microsites that go dark.
Sources
Related guides
Take the free readiness check
About 4 minutes. Get a score, category timeline (confirmed vs expected), and a prioritised gap checklist.
Educational readiness check only — not legal advice. Category timelines change as delegated acts are adopted. Confirm obligations with counsel for your product group.