How do I give each product a unique identification code?
A code that links product, manufacturer and source together
Each product will soon not receive one simple number, but a combination of identification codes that together refer to the digital product passport of that specific product. Article 12 of the ESPR (Regulation (EU) 2024/1781) calls this the unique identifier: a code that makes it possible to go directly from the physical product or packaging to the associated passport. That code does not stand alone. Article 11 of the same regulation describes how the passport is technically structured and how it works, and the unique identifier is the component within it that makes the passport findable and distinguishable from all other passports. For a manufacturer or importer of aluminium semi-finished products, this means in practice that not only the product itself receives a code, but it must also be clear who placed the product on the market and, where relevant, where it was produced.
For whom and which aluminium product this applies
This obligation applies to products for which a digital product passport is actually made mandatory through a delegated act under the ESPR. As long as that delegated act for aluminium semi-finished products — profiles, castings, packaging aluminium — is not yet in place, there is also no legal obligation to assign a unique identifier according to this article. Moreover, this specifically concerns the identification that unlocks the passport, not other codes that a company already uses, such as internal article numbers, batch numbers for quality control, or customs codes. Those existing codes may play a role as a building block later, but are not in themselves the unique identifier that Article 12 means. The distinction is relevant: a company that already has well-documented batch data is better positioned, but has not thereby automatically complied with what will later be required.
No fixed date yet, but a clear timeline
There is no date yet on which this obligation enters into force for aluminium semi-finished products. The ESPR itself is in force at EU level, but which product groups need a digital product passport — and thus a unique identifier — and when, is regulated separately for each product group via a delegated act. For aluminium, that act is on the European Commission's work plan for 2025-2030, with an expectation that it will be published in 2027. Until that delegated act is in place, there is no concrete obligation for aluminium under Article 12. Once the act is published, the date will be stated here as soon as it is fixed.
The order in which this is typically tackled
Those wishing to prepare for this should not start with the code itself, but with the question of which data are already recorded somewhere in the organisation and to which product, batch and production location those data are linked. A logical sequence is: first determine which products or product groups will fall under the upcoming delegated act for aluminium. Then map out who is the manufacturer or importer for those products within the meaning of the ESPR, and whether multiple production locations are involved that must be separately identifiable. Next, it is useful to review which identification systems already exist in-house — batch numbers, internal article codes, existing links with suppliers — because these can serve as a basis once it is clear what form the unique identifier must take according to the final rules. Alupas.eu compiles the passport based on the data supplied by the manufacturer or importer and provides the QR data carrier with which the code is physically linked to the product; this step only comes into play after the delegated act provides clarity on the precise requirements for the code.
Supporting evidence: Article 12 and Article 11 of the ESPR
The obligation for a unique identification code is set out in Article 12 of Regulation (EU) 2024/1781 (ESPR). How this code relates to the rest of the digital product passport — the way the passport is technically structured, linked and accessible — follows from Article 11 of the same regulation. Both articles only take concrete effect once a delegated act is adopted for a product category that makes the passport mandatory for that category; the ESPR itself establishes the framework, the delegated act fills this in per product category.
Anyone wishing to get started now should begin by putting their own product registration in order: which product belongs to which batch, which production site and which existing code. Once the delegated act for aluminium has been published, the concrete date will be stated here and it will be described what form the unique identification code must then take.
What this is based on
- Regulation (EU) 2024/1781 (ESPR), Article 12 (unique identification code)
- Regulation (EU) 2024/1781 (ESPR), Article 11 (technical design and operation of the digital product passport)
The regulation itself is on EUR-Lex. We refer per statement; you do not have to take our word for it.
What you must concretely do
What is expected of you
Each product receives its own unique identification code
Article 12 of the ESPR (Regulation (EU) 2024/1781) stipulates that the digital product passport must contain a unique identification code with which the product can be identified. For a company that manufactures aluminium profiles, castings or packaging semi-finished products, this means that a system must be put in place to assign this code — consistently, and ensuring that two different products (or batches, depending on how they are registered) do not accidentally receive the same code. With a production of tens to hundreds of orders per year, this is no longer a matter of loose Excel numbering; it requires a fixed, repeatable coding method that everyone in the company applies in the same way. The question of whether this happens per item or per batch is linked to what is practically feasible for the production line — this will be worked out further on the page about register per batch or per unit.
The code must comply with a recognised standard
Article 12 refers to identification systems that comply with international or European standards, so that the code can not only be recognised and looked up internally but also by partners, supervisory authorities and the public. In practice, many companies already work with GS1 structures for logistics or invoicing; the question is whether that structure is also suitable as a carrier of the product passport code. That subject — whether an existing GS1 number can be reused or whether something separate is needed — is addressed on the page about GS1 Digital Link.
The code must be linkable to the register and to the QR code on the product
Article 11 of the ESPR describes the technical requirements for the passport, including that the passport must be accessible via a data carrier on the product. The unique identification code is the link between that data carrier (usually a QR code), the passport itself, and the entry in the European register. For a company, this means that the code must not only "match somewhere internally", but must also work technically into what will eventually be affixed to the aluminium — see the page about the QR code on the product — and into what is supplied to the European register.
The code must remain stable for as long as the product exists
A unique identification code only has value if it does not change halfway through. Article 12 is based on a code that permanently identifies the product, including when information in the passport is later amended. For a company, this means that a distinction must be made between the code (which remains fixed) and the content of the passport (which can change) — this distinction is covered on the page about amending data after publication.
Where things go wrong in practice
Duplicate numbering between production lines. A foundry that produces both castings and packaging components sometimes uses its own numbering sequence per department that is logical internally but not unique externally. Once both sequences are brought together at a third party (customer, recycler, supervisory authority), confusion arises about which product belongs to which code.
Batch code confused with product code. With aluminium semi-finished products, a batch or melt number is often already used for quality control. That number is then reused as the passport identification code, without consideration of whether the level of uniqueness (batch versus individual item) matches what the passport requires.
Code changes during repacking or repackaging. When aluminium profiles are cut, repacked or resold in smaller units, a new internal code is sometimes assigned without clarity on whether this creates a new product (with a new passport) or remains part of the same product.
No link between code and the ERP system. The identification code is maintained manually in a separate file, separate from the system in which orders, inventory and invoicing run. As the company grows or staff changes, that link is quickly lost or becomes inconsistent — a risk that diminishes when the code is recorded in the place where it is anyway linked to its own ERP or inventory system.
Code not retrievable after years. An aluminium profile can remain in use for a long time before it resurfaces, for example during recycling. If the code only existed in an internal system at that time, and that system has since been replaced or is no longer accessible, the link between the physical product and the passport is broken.
What you can document now
- An internal coding protocol: how the unique identification code is constructed, who assigns it, and at what level (piece, batch, order) this happens.
- An overview of which existing numbers (melt number, batch number, order number) are or are not reused as the basis for the identification code, and why.
- A recorded link between the identification code, the QR data carrier on the product and the passport in the register, so that in the event of an inspection or customer inquiry it is quickly clear which passport belongs to which product.
- Agreements on what happens to the code when an aluminium semi-finished product is processed, cut up or repacked, so that it is clear whether this results in a new product with a new code.
- A record of how long and where the identification code remains traceable, also when internal systems are replaced — relevant in connection with the question of how long a passport must remain available.
- A template for assigning codes to new products, so that this does not depend on the knowledge of one employee.
This is not legal advice. This page provides general information on the legislation that this platform covers. 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, checked by a human on 2026-08-22. Is something not right? Let us know — corrections are prioritised.