DPP unique IDs and data carriers

What ESPR requires for unique product identifiers and data carriers — and what is left to product-specific delegated acts. Educational readiness guidance, not legal advice.

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.

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.

  • 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

Take the free readiness check

About 4 minutes. Get a score, category timeline (confirmed vs expected), and a prioritised gap checklist.

Start the DPP Readiness Checker

Educational readiness check only — not legal advice. Category timelines change as delegated acts are adopted. Confirm obligations with counsel for your product group.