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What is GS1 Digital Link and do I need it for the digital product passport?

GS1 Digital Link links a product code to a web page

GS1 Digital Link is a technical standard from GS1, the organisation behind the well-known barcodes and GTIN numbers. The standard describes how to process a product identification code (such as a GTIN) into a web address, so that a QR code containing that web address leads to a page with information about that specific product. In retail and logistics, this is already a common way to use one QR code for both the checkout and a customer who wants to know more. For the digital product passport under the ESPR, this is relevant because the regulation itself also requires a link between a unique identification number and a data carrier — usually a QR code — that refers to the passport data. GS1 Digital Link is therefore not an obligation from the ESPR itself, but an existing, widely used way to technically do exactly what the regulation requires.

For the data carrier, not for the content of the passport

GS1 Digital Link concerns the way a code on a product — the data carrier, usually a QR code — refers to a web page with data. It is not about which data must be included in the product passport, how long that data must be retained, or who may access it. Those are other parts of the ESPR and of the product-specific delegated acts that follow. GS1 Digital Link is also not an exclusive or mandatory standard for the product passport: Article 12 of the ESPR (Regulation (EU) 2024/1781) requires that there be a unique identification code, and Article 11 of that same regulation determines that the Commission shall establish technical requirements for the design and operation of the data carrier. Which technical standard is precisely prescribed for this is set out in that further implementation, not already in the base text of the regulation. For furniture, that implementation has not yet been published; until then, there is therefore no established requirement that GS1 Digital Link, or any other specific standard, is mandatory.

Technical specifications to follow from a delegated act

Article 11 of the ESPR determines that the Commission shall establish, through delegated acts, the technical requirements for the design and operation of the data carrier and the unique identification number. That act has not yet been published for furniture. Until that publication, it is not certain whether, and if so how, GS1 Digital Link will be prescribed or permitted alongside other standards. What is certain, however, is the principle in Article 12: there must be a unique identification code that unambiguously links the product and the associated passport data to each other. GS1 Digital Link is one of the existing technical ways to shape that link, and is already widely used in practice, even outside the ESPR. As soon as the technical implementing act for furniture is published, it will be stated here specifically which standard applies.

What a manufacturer or importer can do with it now

Anyone already working with GTIN numbers via GS1 has a head start: these are precisely the kind of unique numbers that Article 12 has in mind, and the associated Digital Link structure is already designed to refer to a product page with further data. For those not yet using GS1 numbers, it is not an obligation to acquire them now: the final technical requirement will only come with the delegated act. In practice, the order is usually as follows: first get your own product data in order — materials, origin, repair information and the like — and only then the question of how to technically unlock that data via a QR code. A platform that compiles the passport and provides the QR data carrier processes the standard that is ultimately prescribed; that is not a choice that an individual manufacturer or importer has to make or fix now.

The basis: Articles 11 and 12 of the ESPR

Article 12 of Regulation (EU) 2024/1781 (ESPR) requires a unique product identifier for the product to which the digital product passport relates. Article 11 of the same regulation provides that the Commission shall establish the technical requirements for the design and operation of the data carrier and that identification number by delegated act. GS1 Digital Link itself is not mentioned in these articles; it is an existing market standard that can serve as a technical implementation of those obligations, without the basic regulation making that choice in advance.

Those who wish to prepare now would do well to get their own product data in order and keep an eye on when the delegated act for furniture is published — at that point it will become clear which technical standard will apply to the QR data carrier.

This is based on

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

GS1 Digital Link is not a separate mandatory component of the product passport, but a technical standard for how a QR code or other data carrier directs to information. The ESPR specifies in Article 11 what the digital product passport must technically comply with, and in Article 12 what the unique identification code of a product must look like. GS1 Digital Link is one of the ways to meet those technical requirements, built around existing GS1 identification codes such as the GTIN.

A data carrier that directs to the passport

Article 11 of the ESPR calls for a data carrier — usually a QR code — that directs to the product passport. GS1 Digital Link is a way to structure that reference so that one and the same QR code can serve multiple purposes: a scan by a consumer can lead to product information, while a scan in the warehouse leads to inventory data. For a furniture manufacturer, this means that the choice for GS1 Digital Link is primarily relevant if GS1 codes are already being used, for example because a wholesaler or retailer requests it. How that data carrier ends up on the furniture itself is described on the page on the QR code on the product.

A unique identification code per product

Article 12 of the ESPR calls for a unique identification code to distinguish a product from other products. GS1 uses the GTIN for this, a code that is often already used in the furniture industry for logistical purposes. For a company with 10 to 100 employees, this means that in practice it must be assessed whether the existing product coding is suitable to serve as a basis for the identification code that the passport requires, or whether an additional structure is needed. More information on the requirements for that code can be found on the page on the unique identification code per product.

Connecting to existing systems

Anyone already working with GS1 codes in an ERP system, inventory management or e-commerce has with GS1 Digital Link a reference point to connect the product passport to it without setting up a completely parallel system of identification codes. This is especially practical for companies that have been working with GTINs for years towards suppliers or retail partners. How that connection to your own system looks in practice is described on the page on linking to your own ERP or inventory system.

Where things go wrong in practice

A first situation is that a company assumes that GS1 Digital Link is mandatory because it is mentioned so often in the context of product passports. The ESPR itself does not prescribe a specific technical standard in Articles 11 and 12; that standard must still be further defined. An assumption that one particular technology is the only way leads to unnecessary investments at a time when the exact requirements are not yet fixed.

A second situation arises when a company already has a GTIN structure, but has never aligned it with the requirement that the identification code must be unique per product as intended in Article 12. A GTIN assigned at model level, rather than at the level of an individual sold product, does not automatically comply.

A third situation is that the QR code is indeed structured according to a GS1 structure, but the underlying link does not remain accessible over a longer period of time. A product passport must remain accessible for the duration of its term; exactly how long that is is explained on the page on how long a product passport must remain available. A technically correct GS1 Digital Link structure says nothing about whether the server behind it will still be active after years.

A fourth situation is that different departments within a company — sales, logistics, compliance — each have their own idea of which code is "the" product code, resulting in multiple identification codes existing alongside each other for the same product. This makes it difficult to determine afterwards which code should be included in the passport.

A fifth situation concerns furniture consisting of multiple parts, such as a cabinet with separately sold shelves or a sofa with loose modules. If it has not been established in advance whether the identification code is assigned at the level of the whole or of the individual part, this creates uncertainty about where which QR code ends up. This directly relates to the question discussed on the page about furniture consisting of loose parts.

What you can put in order now

  • An overview of which product codes (GTIN or otherwise) are already in use within the company, and at which level — model, variant or individual product — those codes are assigned.
  • An agreement about who within the company is responsible for assigning new identification codes, so that a different code does not arise per department for the same product.
  • A description of how the existing product coding relates to the requirement of a unique identification code per product, including any adjustments that may be necessary for this.
  • A documented agreement with the party that technically sets up the QR code or data carrier, about which standard is used and why.
  • A note on the link between the product passport and internal systems such as ERP or inventory management, so that in case of a system change it is clear which data comes from where.
  • Documentation on how products are handled that change after publication of the passport, for example with a changed formulation or composition — relevant in combination with the information on the page about changing data after publication.

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.