How do I assign a unique identification code to each product?
Each product receives a unique code that refers to its passport
A piece of furniture receives a unique identification code that links the product to its digital product passport. This code ensures that anyone consulting the passport — via the QR data carrier on the product — reaches the correct, up-to-date information for that specific product or product batch, and not an incorrect or outdated passport. The code itself is therefore not a design choice that you can freely determine: it must be structured in such a way that each passport can be unambiguously linked to one product or product group, and that this link remains valid for ten years.
For physical products within a product group, not for services
The obligation to provide a product with a unique identification code applies to products that fall under the digital product passport once a delegated act enters into force for that product group. This is not yet the case for furniture. The code belongs to the physical product (or, where the legislation permits, to a batch or model) and not to the packaging, the carrier or the shop where it is sold. Services, such as assembly or maintenance of a piece of furniture, do not fall within this scope — the passport and the identification code belong to the product itself. For product groups for which no delegated act has yet been established, no obligation to use a unique identification code currently applies.
The date follows from the work plan, not yet established
When furniture must be required to receive a unique identification code depends on the moment when the European Commission adopts and publishes the delegated act for the product group of furniture. According to the work plan of the ESPR for the period 2025-2030, that act is expected in 2028, but this is a planning estimate and not a binding obligation with a fixed date. As long as that act does not exist, there is no legal obligation for furniture to have a digital product passport, and therefore no obligation to use a unique identification code as referred to in Article 12 of the ESPR. As soon as the act is published, the date will be mentioned here.
How the code comes about in practice
Anyone preparing for this should not start with the code itself, but with the question of what level of detail is needed: does the passport apply per individual product, per production batch, or per model. This choice determines how the identification code is structured and how many unique codes are needed. Next, it is necessary to determine which system generates and maintains the code — often this is the manufacturer's existing ERP or production system, supplemented with a link to the passport. This link must be set up in such a way that the code never points to a blank or incorrect passport; this is also why the code and the passport content are not set up separately in practice. This is followed by the question of how the code is printed or applied: as part of the QR data carrier on the product, so that scanning this code leads directly to the correct passport. Finally, it is important that the code and the underlying link are retained for as long as the passport must be available — with Furnipas this is ten years of hosting, so the identification code must remain stable and traceable for just as long as the passport itself.
The basis: Article 12 and Article 11 of the ESPR
The obligation for a unique identification code is laid down in Article 12 of the ESPR (Regulation (EU) 2024/1781). Article 11 of the same regulation governs the technical design and functioning of the digital product passport in a broader sense, including the requirements for the data carrier on which the identification code is affixed and the way in which passport, data carrier and identification code are technically aligned. Both articles work together: Article 12 determines that there must be a unique code and what it must be able to do, Article 11 determines how that code is technically carried and accessed. For product groups such as furniture, the delegated act for that group specifies in more detail how these general requirements are concretely applied.
If you want to prepare now, you can already map out at which level — product, batch or model — your own production lends itself to a unique code, and which existing system could generate and maintain that code. Once the delegated act for furniture is published, this will be supplemented with the concrete requirements that follow from it for the structure of the code and the link with the passport.
This is based on
- Regulation (EU) 2024/1781 (ESPR), Article 12 (unique product identifier)
- Regulation (EU) 2024/1781 (ESPR), Article 11 (technical design and operation of the digital product passport)
The regulation itself is available on EUR-Lex. We refer per statement; you do not need to believe us.
What you concretely have to do
What is expected of you
Each product receives its own unique identification code
Article 12 of the ESPR (Regulation (EU) 2024/1781) describes that a product falling under the digital product passport is provided with a unique identification code. For a furniture manufacturer or importer, this means that not only does the product model have a name or type designation, but a code system will also be introduced that distinguishes a specific specimen (or a specific batch, depending on how the passport is structured) from all other products ever registered. For a company with 10 to 100 employees, this usually means that the current article number or SKU system is reviewed: many existing numbering systems are designed to distinguish product variants, not to give each physical specimen or each production batch its own code.
The code must align with the technical design of the passport
Article 11 of the ESPR describes the technical requirements that the digital product passport as a whole must meet, including the way in which the identification code is linked to the data carrier (such as a QR code) and to the passport itself. This means that the identification code does not stand alone: it must work within the system used to access the passport. Those wondering how the QR code for the product passport gets onto the furnituresoon encounter the question of how that code relates to the identification code recorded in the passport itself — these are two sides of the same link.
The code must remain unique, even in the long term
An identification code that is unique today must remain so over the years. This requires a system in which numbers are not reused, even if a product is phased out or a collection is discontinued. For a company with a manageable product inventory, this can be tracked with an internal register; as the number of variants and batches grows, managing that uniqueness becomes a task that can no longer be left to one person with a spreadsheet.
The link with existing identification systems
Many furniture companies already work with barcodes, EAN or GS1 codes for logistics and inventory management. The question what GS1 Digital Link is and whether it is necessary for the product passport directly arises here: an existing identification system can serve as a basis, but must then meet what Article 12 of the ESPR requires in terms of uniqueness and linking to the passport. That is different from an internal article number that only has meaning within your own ERP system.
Where things go wrong in practice
A manufacturer uses the existing SKU number as the identification code for the passport, without recognising that this number is repeated for multiple product variants or production years. The result is that multiple physical products share the same code, while the passport assumes that the code identifies one specimen or batch.
An importer has the identification code generated by a supplier in a third country, without documenting how that code is constructed or who guarantees that it will never be issued twice. When it later emerges that two shipments happen to have used the same series of numbers, it is no longer possible to trace where the error originated.
A company changes software supplier for inventory management and with it also changes numbering logic, without archiving the old identification codes. For products that already had a passport, this creates a gap between the code on the QR code on the furniture and the code that the new system uses internally.
A project furnisher orders furniture in small batches with minor modifications (fabric, colour, finish) and treats each order as 'the same article', when the question of whether the furniture as a whole or each component receives its own passport actually needs to be answered first before it becomes clear how many identification codes are needed.
A manufacturer records the identification code internally, but forgets to consistently link it to the moment the product passport is published or modified, making the question whether data can be adjusted after the passport has already been published no longer unambiguously answerable because it is unclear which code corresponds to which version.
What you can put in order now
- An overview of the current article numbering or SKU system, with an assessment of whether it already meets a requirement of uniqueness per unit or per batch.
- A choice of identification code type (own numbering, GS1-based, or another system) and the reason for that choice.
- An internal register recording which identification code has been assigned to which product, which batch and which production date, so that numbers are never unintentionally reused.
- Agreements with suppliers or import partners about who assigns the identification code and how duplicate assignment is prevented.
- A documented link between the identification code and the data carrier on the product, relevant for anyone figuring out how the QR code is applied to the furniture.
- A procedure for what happens to the identification code when software, ERP system or supplier changes, something that relates to the question of whether the product passport can be linked to your own ERP or inventory system.
- An archive of issued codes, including those of products that are no longer produced, so that uniqueness remains demonstrable in the long term.
This is not legal advice. This page provides general information about the legislation that this platform concerns. We do not know your situation. If in doubt about your own case, consult a lawyer or the competent supervisory authority.
Written with AI based on the sources above, reviewed by a human on 2026-08-22. Is something wrong? Let us know — corrections take priority.