What is GS1 Digital Link and do I need it for the digital product passport?
A technical standard for the QR code, not an obligation in itself
GS1 Digital Link is a technical specification that enables a barcode or QR code to contain not only an identification number, but also a web address. If you scan the code with a standard smartphone, a web page opens; if you scan it with business software, the same code can be read as a conventional product code. One data carrier, two uses. For the digital product passport, this is attractive because Article 11 of the ESPR (Regulation (EU) 2024/1781) requires a data carrier that provides access to the passport, and Article 12 requires a unique product identification code. GS1 Digital Link is one way to combine these two requirements in a single QR code. The ESPR itself does not mandate this brand or format; the regulation is technology-neutral and leaves the precise technical implementation to later, product-group-specific rules.
For whom this is relevant, and for whom it is not (yet)
GS1 Digital Link is relevant for anyone now thinking about how the QR code on an aluminium profile, casting or packaging component will look in the future, and who also wants to reuse this code for logistics, inventory management or customer communication. For this combination of purposes, GS1 Digital Link is a logical candidate, because it aligns with existing GS1 numbering systems (GTIN, GLN) that are already in use in many supply chains. It is not relevant, or at least not mandatory, for those who only want to meet the bare requirement of Articles 11 and 12: a readable data carrier with a unique code that references the passport. In principle, this requirement can also be met with a different type of QR code or another identification standard, as long as the product-group-specific delegated act does not prescribe a specific standard. Which standard will ultimately be mandatory or recommended for aluminium semi-finished products is not yet fixed: that is precisely the kind of technical detail that is worked out in the delegated act per product group, not in the ESPR itself.
No fixed date yet, and no fixed standard yet
No delegated act has yet been published for aluminium semi-finished products, and therefore no definitive choice for a data carrier standard for this product group. According to the Commission's work plan for 2025-2030, that delegated act is expected around 2027, with the associated obligations at the earliest around 2029 — but this date is also not yet fixed. Until the act is in place, there are no mandatory requirements for the form of the data carrier for aluminium products. What is fixed, however, is the general framework from Articles 11 and 12: a data carrier that provides access to the passport, and a unique identification code that links the product to the correct information. How these two requirements are technically implemented — with GS1 Digital Link, with another standard, or with a format prescribed by the Commission — will only become clear once the product-group-specific rules are published.
What to do until that clarity is available
If you are already speaking with suppliers or software partners about the digital product passport, the conversation is best conducted in this order. First: which identification codes are already in use in your own supply chain, for example GTINs or internal article codes, and are they unique enough to serve as a basis for the identification code from Article 12. Next: is the existing QR code or barcode on products and packaging technically capable of carrying, alongside its current function, also a link to a web page — that is precisely where a standard such as GS1 Digital Link proves its value, because it does so without double encoding. Then: inquire with a software supplier or GS1 member organisation whether they already have pilots or guidelines for digital product passports, without prejudging a choice that the Commission still has to make. Finally: monitor the publication of the delegated act for aluminium, because only then will it become clear whether a specific standard is made mandatory or whether the choice remains free within the framework of Article 11.
The legal basis: Articles 11 and 12 of the ESPR
The requirement that the digital product passport must be accessible via a data carrier, and that this data carrier must technically meet certain conditions, is set out in Article 11 of the ESPR (Regulation (EU) 2024/1781), which covers the technical design and functioning of the digital product passport. The requirement that each product receives a unique identification code that links the passport to the specific product is set out in Article 12 of the same regulation. Both articles describe the purpose and functional requirements, not the exact technical format. GS1 Digital Link is therefore not a legal term from the ESPR, but an existing industry standard that aligns with what these two articles require.
If you are making decisions about data carriers at this time, it is best to ask whether GS1 Digital Link is already part of your own software or GS1 membership, and to monitor the development of the delegated act for aluminium via the official EUR-Lex page of the ESPR.
What this is based on
- Regulation (EU) 2024/1781 (ESPR), Article 11 (technical design and operation of the digital product passport)
- Regulation (EU) 2024/1781 (ESPR), Article 12 (unique identification code)
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
GS1 Digital Link is not a separate legal requirement — the term does not appear in the ESPR. It is a technical way to structure a barcode or QR code so that a single scan both points to a unique identification code and to a web page, such as the product passport. Article 11 of the ESPR (Regulation (EU) 2024/1781) specifies what the data carrier and passport must technically comply with, without prescribing a specific standard such as GS1. Article 12 governs the unique identification code associated with the product. GS1 Digital Link is one way to combine those two things — code and passport — in a single QR code.
The QR code must point to the correct data
What Article 11 does establish is that the data carrier on the product leads to the product passport. For a company with 10 to 100 employees, this means a choice: do you use a simple link (a URL to a web page), or a structured link according to the GS1 Digital Link standard, in which, for example, the article number, batch and serial number are already incorporated into the URL itself? Both can work in practice; GS1 Digital Link has the advantage that the same QR code is also recognized by existing scanning systems in the sector, because that standard is already widely used in logistics and trade. You can read more about how that code ends up on the aluminium in how does the QR code for the product passport end up on my aluminium.
The unique identification code must align with the passport
Article 12 calls for a unique identification code per product (or batch, depending on how it is registered). GS1 Digital Link provides a standardized structure for this: a GTIN (Global Trade Item Number) supplemented with batch or serial number, embedded in the link itself. For a profile manufacturer or foundry that already works with GS1 barcodes for logistics, this saves double work — the same identification can serve for inventory management and for the passport. Those who do not yet use GS1 numbers must first apply for them from GS1, and that is a choice separate from the ESPR obligation itself. How that identification code is precisely structured is described in how do I assign a unique identification code to each product.
The passport must align with the register
In addition to the link on the product itself, information about the passport must also be submitted to the European register. A GS1 Digital Link can help with this because the structured identification code is easier to link automatically to a register entry, instead of someone having to manually retype the data. What exactly must be included in that register is separate from which type of link is used and can be found at what is the register of digital product passports and what must I enter in it.
Where things go wrong in practice
A foundry has an IT supplier create a QR code that points directly to a static pdf, without any structure. That works for one product, but as soon as there are a hundred product variants, there is no consistent way to manage those codes or link them to a system.
A profile company has been using GS1 barcodes for logistics for years, but the new QR code for the product passport is set up separately by another department. The result: two different identification systems side by side on the same product, which is confusing for everyone who scans.
A packaging aluminium producer thinks that GS1 Digital Link is mandatory because a supplier communicates it that way, and pays for an expensive implementation while a simpler link could also have complied with article 11. Money is invested in complexity that does not follow from the regulation itself.
A company sets up the GS1 Digital Link correctly, but forgets that the underlying URL must remain functional when the passport is updated or when the company later ceases operations. The code on thousands of already sold products then points to a dead link. What can be arranged in this regard is detailed at what happens to the digital product passport if my company stops operating.
A company opts for GS1 Digital Link without considering integration with its own ERP system, as a result of which batch data must be entered manually instead of being synchronized automatically. See in this regard can I link the digital product passport to my ERP or inventory management system.
What you can document now
- An overview of which identification standard is used (GS1 Digital Link, a proprietary URL structure, or something else) and why that choice was made.
- The link between the GTIN or internal product code and the batch or serial numbers included in the link, so that it remains traceable which product corresponds to which code. This aligns with the choice to register per batch or per unit.
- Agreements with the IT supplier or internal ICT department on who generates, manages and tests the links when changes are made.
- A procedure for what happens if data in the passport is adjusted after publication, so that the QR code on the product continues to refer to current information — see how do I update data in a product passport that is already published.
- Test results demonstrating that the QR code is readable with different scanners (mobile phone, handheld scanner, GS1-compatible apps) and leads to the correct page.
- A list of which systems (ERP, inventory management, GS1 membership) already provide existing identification codes, so that duplicate or conflicting numbering is avoided.
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.