What is traceability?

Traceability is the ability to follow a product through recorded information. ISO 9000:2015, the quality management vocabulary, defines it as the ability to trace the history, application or location of an object. For a physical product, that covers three things: where its materials and parts came from, how and where it was made, and where it went after delivery.

People usually mean one of two things by it:

• Product traceability: following one product, batch or unit, for example to find every unit affected by a faulty part.
• Supply chain traceability: joining the records of every company in the chain, from farm, mine or mill to the final customer, for example to show that a material comes from a specific region or facility.

How traceability works

Traceability rests on two building blocks: identifiers and records.

1. Identify the product. A model number or GTIN identifies the product type. A batch or lot number identifies a production run, and a serial number identifies one unit.
2. Record events. Each company records what happened to the product: what it received and from whom, what it made or changed, and whom it supplied, with a date and place.
3. Link the records. Shared identifiers let records from different companies be joined into one history. Standards such as GS1 EPCIS and the UN Transparency Protocol define a common format for these events.

The simplest form is one step up, one step down: every company knows its direct supplier and its direct customer for each product. If every link keeps that record, the full chain can be reconstructed when needed. Full chain traceability goes further and passes origin data forward with the product, so the brand can see the whole chain without asking each link.

Batch level or item level

The level decides how precisely you can act on a problem.

• Model level: one identifier for all units of a product type. Enough for product information, not for recalls of part of production.
• Batch level: one identifier per production run. A recall can be limited to the affected batches.
• Item level: one identifier per unit. Each unit's history, owner, repairs and condition can be followed on its own.

Under ESPR, each product group's delegated act sets whether the Digital Product Passport is kept at model, batch or item level (Article 9(2)(d)). The battery passport is kept per individual battery.

Which EU laws require traceability

• GPSR (Regulation (EU) 2023/988). Manufacturers must put a type, batch or serial number on products (Article 9(5)). Every economic operator must be able to tell market surveillance authorities who supplied them and whom they supplied, for six years (Article 15(3) and (5)). Article 18 lets the Commission require specific traceability systems for products that present serious risks. These records are what make a targeted product recall possible.
• EUDR (Regulation (EU) 2023/1115). Operators placing cattle, cocoa, coffee, oil palm, rubber, soya, wood and products made from them on the EU market must give the geolocation of the plots of land where they were produced. The main obligations apply from 30 December 2026 for medium and large companies.
• EU Battery Regulation (Regulation (EU) 2023/1542). Supply chain due diligence for raw materials such as cobalt, lithium and nickel applies from 18 August 2027, after the postponement in Regulation (EU) 2025/1561.
• Forced Labour Regulation (Regulation (EU) 2024/3015). From 14 December 2027, products made with forced labour cannot be placed on the EU market or exported. It creates no new due diligence duty, but authorities can ask companies what they did to identify, prevent and end forced labour risks in their operations and supply chains (Article 17), and answering needs supply chain records.
• ESPR (Regulation (EU) 2024/1781). The rules for each passport must improve the traceability of products along the value chain (Article 9(3)(c)).

Traceability and the Digital Product Passport

The passport does not replace supply chain records, but it gives them a public anchor. Each passport is connected through a data carrier, usually a QR code, to a persistent unique product identifier. That identifier is the key that links production events, supplier data and later life cycle events, such as repairs or a change of owner, to the physical product.

How to prepare

1. Choose your level per product group: model, batch or item, based on the delegated act where one exists and on what you need for recalls and service.
2. Mark every unit with a batch or serial number that matches your records, and put it in the QR code where you can.
3. Keep supplier and customer records for each batch for at least six years.
4. Collect origin data from suppliers, such as facilities and material sources, in a structured form you can reuse.
5. Record events in a standard format, such as EPCIS or UNTP, so partners and authorities can read them.