QR code on the product: is it already Digital Product Passport-ready? A practical guide to the data carrier under the ESPR

Why this question is crucial

Among the questions that guide the design of a Digital Product Passport (DPP), one may seem trivial, yet it carries very concrete implications: does your product already feature a data carrier?

A data carrier is a machine-readable medium—typically a QR code—that links a physical object to its digital passport. Without it, the DPP remains an inaccessible database; no consumer, repair technician, recycler, or authority would be able to retrieve the relevant information starting from the product they hold in their hands.

Providing an accurate answer helps establish your starting point: whether an existing infrastructure can be adapted, or if a new one must be designed from scratch—a process that impacts graphic design, labeling, production lines, and information systems.

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The three possible starting scenarios

1. "Yes, we already have a QR code"

This is the most common scenario: a QR code printed on the product or its label that directs users, for instance, to a product page on the company website.

However, take note: having a QR code does not necessarily mean having a compliant data carrier. You should ask yourself the following questions:

• What does it encode? A simple marketing URL does not constitute a unique and persistent product identifier.
• Is it persistent? If the link points to a page that changes whenever the website is updated, the connection risks breaking over time. The passport must remain accessible for the long term—ideally, for the entire lifespan of the product.
• At what level does it provide identification? Using the same QR code for every unit of a given model is only acceptable if the delegated act for your specific sector mandates a passport per model. If the requirement is for a passport per batch or per individual item, a serialized code is necessary. - Does it follow a standard? The identifier must comply with the standards referenced in the regulation (specifically the ISO/IEC 15459 family).

Often, the solution is not to add a second code, but rather to redesign the existing one—for example, by adopting the GS1 Digital Link syntax: a single QR code that contains the GTIN (along with the batch or serial number, if needed) within a resolvable URL. This same code can then serve the point-of-sale, the consumer, and the product passport.

2. "Yes, but what about another medium (RFID, NFC, Data Matrix…)?"

Some companies already use RFID tags in their labels (common in fashion and logistics), NFC chips (for anti-counterfeiting or interactive experiences), or Data Matrix codes (widespread in industrial and pharmaceutical sectors).

While these are all potentially valid media, they must be evaluated carefully:

• Accessibility: A QR code can be read by any smartphone, whereas a UHF RFID tag requires a dedicated reader. If the product passport is intended to be accessible to the end consumer, this is a significant factor.
• What the delegated act stipulates: Product-specific regulations will define which media are permitted for each category.
• Combination: In many cases, the most robust approach is to pair an "industrial" medium (such as RFID) with a "universal" one (such as a QR code), provided that both point to the same identifier.

3. "No, no code at all (or just a standard barcode)"

A traditional linear barcode (EAN/UPC) contains only the item code; it does not link to any web resource, nor does it distinguish between batches or individual units. For the purposes of the Digital Product Passport (DPP), this is effectively the same as having no data carrier at all. Starting from scratch, however, offers one advantage: the correct solution can be designed from the outset, without the need to manage migrations from "legacy" code. Key decisions to be made include:

• the type of data carrier;
• the level of granularity (model, batch, or individual item);
• where it should be applied (on the product, packaging, or documentation);
• the resolver service, which directs each scan—based on the identifier—to the appropriate content.

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What the regulations say

The ESPR Regulation (EU) 2024/1781

The Ecodesign for Sustainable Products Regulation (ESPR) provides the overarching framework for the Digital Product Passport. Regarding the data carrier, it establishes several essential principles (Article 10):

• the passport must be linked, via a data carrier, to a unique and persistent product identifier;
• the data carrier must be physically present on the product, its packaging, or the accompanying documentation, as specified by the applicable delegated act;
• the data carrier and identifier must comply with the standards set out in Annex III (or equivalent European/international standards, pending the adoption of harmonized standards);
• the data within the passport must be based on open, interoperable standards, ensuring no vendor lock-in.

A common point of confusion: the data carrier contains only the identifier, not the passport data itself. A QR code does not "contain" the product’s environmental profile; rather, it holds the key to accessing it. This allows the data to be updated without the need to reprint labels.

The ESPR also provides for a European passport registry, which stores at least a list of data carriers and unique identifiers; therefore, in order to place a product on the market, its identifier must be registered.

The case of batteries: Regulation (EU) 2023/1542

Batteries serve as the first concrete test case. The Batteries Regulation, under Article 13, governs labeling and introduces the use of a QR code:

• from 18 February 2027, all batteries placed on the EU market—including portable batteries and those used for starting, lighting, and ignition (SLI)—must feature a QR code;
• for batteries used in electric vehicles, light means of transport (LMT), and industrial batteries with a capacity exceeding 2 kWh, the QR code must provide access to the battery passport (Art. 77);
• for other categories, the QR code links to a more limited set of basic information.

Consequently, manufacturers and importers of batteries—or products containing them—face a firm and imminent deadline.

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"Generic" QR codes vs. compliant data carriers

Aspect	Marketing QR code	Data carrier for the DPP
Content	URL of a webpage	Unique and persistent identifier (e.g., GTIN + serial number) in a standard format
Link duration	Tied to the lifespan of the website	Persistent for the duration required by regulation
Granularity	Usually one per model	Model, batch, or individual item, as specified by the delegated act
Standards	None	ISO/IEC 15459 and standards set out in Annex III of the ESPR
Target audience	Consumer	Consumers, repairers, recyclers, and authorities—with differentiated access rights
Registration	Not required	Identifier registered in the EU registry

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Operational Checklist

1. Inventory existing codes on products, labels, packaging, and manuals.
2. Verify what they encode: A generic URL or a structured identifier?
3. Check the level of granularity required by the delegated act for your specific sector.
4. Select an identification standard (e.g., GTIN via GS1 or another ISO/IEC 15459-compliant Issuing Agency).
5. Evaluate GS1 Digital Link to unify point-of-sale codes, consumer experience, and the digital passport.
6. Determine placement: On the product whenever possible; otherwise, on the packaging or documentation, as permitted.
7. Test for readability and durability: The code must remain readable throughout the product's useful life (withstanding washing, abrasion, sun exposure, etc.).
8. Set up a resolver and manage data access rights.
9. Plan for the registration of identifiers in the European registry.

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In Summary

Asking whether a data carrier already exists on a product is not merely a formal exercise; it is the first step toward understanding how much work lies between your company and a functional digital passport. Those who already use a QR code have a head start, though they must ensure it is persistent, unique, and compliant with relevant standards. Those using RFID or NFC must assess their accessibility. Those starting from scratch have the opportunity to design the right solution from the outset. For batteries, time is running out—February 18, 2027, is just around the corner.