A data carrier is the physical link between a product and its Digital Product Passport. It is the code or tag you scan, most often a QR code, that holds the product's identifier and opens its passport online.
The Ecodesign for Sustainable Products Regulation (ESPR) defines a data carrier in Article 2(29) as "a linear barcode symbol, a two-dimensional symbol or other automatic identification data capture medium that can be read by a device". That covers barcodes, QR codes and Data Matrix symbols, as well as RFID and NFC tags.
What ESPR requires
Article 10(1) sets the essential requirements for the passport. For the data carrier, they are:
- It links to a persistent unique product identifier, which cannot change during the passport's lifetime.
- It is physically present on the product, its packaging or documentation accompanying the product, as the delegated act specifies.
- It follows recognized standards: ISO/IEC 15459 parts 1 to 6 listed in Annex III, or equivalent European or international standards, until harmonized standards are published.
Each product group's delegated act then adds the detail (Article 9(2)): which data carriers to use, the layout in which they are presented and where they are positioned.
For batteries, the battery passport is reached through a QR code under the Battery Regulation, with the passport required from 18 February 2027.
Types of data carriers
- QR code: readable by any smartphone camera, holds a full web address, cheap to print. The most common choice for passports.
- Data Matrix: a compact 2D symbol often used on small parts, electronics and healthcare products. It needs a scanner app or industrial reader.
- Linear barcode (EAN/UPC): holds only the GTIN, with no web address and no batch or serial number. Not enough on its own for most passports.
- RFID and NFC tags: readable without line of sight, useful in logistics and for textiles where a printed code may wash out. They cost more per unit.
Many brands combine carriers, for example a QR code on the care label plus an RFID tag for warehouse handling.
One code for checkout and passport
A QR code built on GS1 Digital Link carries the GTIN, and optionally a batch or serial number, inside a web address. Retail scanners read the GTIN, while a phone camera opens the passport. GS1 and retailers are moving checkouts to 2D barcodes, with the industry aim that QR codes with GS1 standards are widely adopted by the end of 2027. A single code then serves the shop, the customer and the regulator.
How to choose and place a data carrier
- Follow the delegated act for your product group once it is adopted. It decides the carrier, position and layout.
- Pick a spot that survives use. A code on the product itself lasts longer than one on packaging that is thrown away.
- Size and contrast matter. Test that the code scans at the size you print, on the material you print on.
- Match the level. Model-level codes can be preprinted. Batch and item-level codes need variable printing on the line.
- Keep the link stable. The web address inside the code must keep working for the full passport period, which is why it should point to a domain you control or a resolver built for this.
- Check the harmonized DPP standards from CEN-CENELEC, which cover data carriers.
How Veribl helps
Veribl creates a GS1 Digital Link QR code for every model, batch and unit, ready to print on labels, packaging or quick-start cards. Each code opens the product's passport, manuals and support page, and keeps working as long as the passport stays online, at least 10 years.
Try the free GS1 Digital Link generatorOfficial sources
Frequently asked questions
What is a data carrier in the Digital Product Passport?
It is the machine-readable code or tag on the product that links to its passport. ESPR Article 2(29) defines it as a linear barcode, a two-dimensional symbol or other automatic identification data capture medium that can be read by a device. In practice most passports use a QR code.
Does the Digital Product Passport have to be a QR code?
ESPR does not fix one technology. Each product group's delegated act specifies which data carriers to use and where to place them. The battery passport is reached through a QR code under the Battery Regulation.
Where must the data carrier be placed?
On the product itself, its packaging or documentation accompanying the product, as specified in the delegated act. The act can also set the layout and positioning.
Can I use the same QR code for retail checkout and the passport?
Yes, if the QR code follows the GS1 Digital Link standard. It carries the GTIN that checkout scanners read and a web address that opens the passport on a phone.
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