How do I give each product a unique identification code?

Each product carrier receives one unique code that refers to the digital product passport

The unique identification code is the characteristic by which a product, and its associated digital product passport, can be distinguished from other products. Article 12 of the ESPR (Regulation (EU) 2024/1781) provides that each product falling under a delegated act shall receive such a code. This code is attached to the data carrier — usually a QR code on a label or sewn-in tag — and refers to the passport drawn up for that product. Without this code, a passport cannot be linked to a single product and the system does not work: the code is the key, the passport is the case it fits.

For textiles and clothing, not regulated separately for each individual garment

The obligation under Article 12 applies to products for which a delegated act under the ESPR has been adopted. This is not yet the case for textiles and clothing; the scope and precise requirements will only be fixed once that act is in place. What does follow from the regulation itself: the identification code belongs to the product to which the passport relates, and the manner in which that product is defined — a single garment, a model, or a batch — is determined in the product-specific rules, not in Article 12 itself. Article 12 describes the requirements for the code, not the question of which products exactly need a passport; the latter is set out in Article 11 and in the delegated act for textiles yet to be published.

No fixed date yet, but a plan is established

There is no date yet for when the obligation to provide a unique identification code for textiles and clothing comes into force. According to the ESPR work plan 2025-2030, a delegated act for textiles is expected in 2027, with clothing consisting of eighty per cent or more textile fibres as the first category. As long as that act is not in place, there is no obligation for textiles under Article 12. Once the act is published, the date will appear here.

Here is how to tackle this once the obligation comes into force

First, it is important to determine at which level a code is assigned: per unique product, per model or per batch. This will follow from the product-specific rules for textiles, not from Article 12 itself — which only determines that the code must exist and the technical requirements it must meet. Next comes the link between code and passport: each code must be uniquely traceable to one passport, so that an inspector or a consumer scanning the QR code gets to the correct data. The question then arises as to who assigns and manages the code; in practice this lies with the party that has the passport drawn up, often the manufacturer or importer, and the code is submitted together with the other passport data to the party hosting the passport and providing the data carrier. Finally, it is important that the code remains stable throughout the entire period during which the passport must be available — for this platform, that is ten years — so that a code is not halfway reused or overwritten for another product.

Where this follows from: Article 12 and Article 11 of the ESPR

Article 12 of the ESPR (Regulation (EU) 2024/1781) establishes the requirement that products with a digital product passport receive a unique identification code and describes its function: making the product traceable to the passport. Article 11 of the same regulation governs the technical design and operation of the digital product passport as a whole, including the data carrier on which the code is affixed and the way in which the passport and code are jointly accessible. Together, both articles form the basis for what will be worked out in the product-specific delegated act for textiles.

If you already work with clothing or textiles, you can make most concrete progress by mapping out at which level — product, model or batch — your own product administration is organized, since that forms the basis once the identification code becomes mandatory. For the current status of the delegated act for textiles, the official ESPR text and the work plan of the European Commission are the place to follow; as soon as there is a published date, it will be processed here.

What this is based on

The regulation itself is available on EUR-Lex. We provide references for each statement; you do not need to take our word for it.

What you must do concretely

What is expected of you

Each product receives its own unique identification code

Article 12 of the ESPR (Regulation (EU) 2024/1781) requires that a product for which a digital product passport is mandatory receives a unique identification code. That code distinguishes the product from all other products and establishes the link with the correct product passport data. For a clothing company, this means that a unique code is not something added afterwards, but becomes part of how a product is created: at the moment an article enters the system, the code that will identify that article throughout its entire lifespan is also created.

The code must comply with recognized systems

Article 12 refers to identification systems that are already used or recognized internationally, so that the code is not an invention of a brand but aligns with a structure that is legible and recognizable to others in the supply chain — customs, market surveillance, trading partners. In practice, this is for many clothing companies the moment when the question arises whether an existing GS1 number is sufficient for this or whether something additional is needed. Anyone wishing to delve into this reads more about what GS1 Digital Link is and whether it is necessary for the product passport.

The code must identify both the product and the passport together

The identification code is not separate from the passport itself. Article 11 of the ESPR describes the technical functioning of the digital product passport, and the unique code is the hinge between the physical product and the digital data that exists about it. For a company with 10 to 100 employees, this means that the code must match in at least two places: in the company's own system in which the article was created, and in the data carrier that appears on the garment itself. How that data carrier ends up on the garment is described on the page about the QR code on the product.

The code must remain unique, even with variants

A clothing collection rarely consists of a single simple article: there are sizes, colours, seasons and sometimes material variants within what is commercially sold as "one product". The obligation to use a unique code directly touches on the question of whether each variant requires its own code — and thereby its own passport. That is precisely where many companies get stuck, and the way this is resolved determines how much administration arises. More about this is on the page that addresses whether each size and colour receives its own product passport.

The code must remain linked to the passport as long as it is needed

A unique code that is correct today but cannot be traced back to the corresponding passport three years later does not meet the purpose of Article 12. The code must remain traceable to the associated passport during the relevant period. This raises questions about how long a passport remains available and what happens to it in the event of business changes — subjects that are addressed separately, but which in practice begin with a consistent code that does not change form or system halfway through.

Where things go wrong in practice

A common situation is that a company uses an internal article number that works perfectly for its own inventory management, but does not align with a system that is externally recognizable. The internal number is then filled in slightly differently by two different departments, and the code loses its function as a unique identification once there is doubt about which version is the correct one.

A second situation arises with private label: an importer has the same clothing line produced by multiple manufacturers and each manufacturer generates its own numbering. Without an agreement on who assigns the code and how it is passed on, the same product receives two different codes, or worse, two different products receive the same code.

A third situation occurs with seasonal collections: a garment that was called "model A, colour blue" last year returns this year with a minor modification and receives the same internal article number because it is "essentially the same product". That makes sense for your own catalogue, but for the identification code it creates ambiguity about which product passport belongs to which physical version.

A fourth situation is that the code is created correctly, but the method behind its creation is not recorded anywhere outside the ERP system. If the person responsible for numbering leaves the company, the knowledge about the logic behind the code disappears, and it becomes difficult to continue numbering new products consistently.

A fifth situation arises when coupling with existing systems: a company wants the identification code to be generated automatically from the ERP system, but has not previously determined which field is the source for this, resulting in the code changing upon a system update while the passport has already been published. How to set up coupling with an existing system for this purpose is described on the page on linking the product passport to an ERP or inventory system.

What you can record

An overview of which identification system is used for the unique code (for example a GS1 structure) and why that system was chosen.
An internal agreement on who within the company is authorised to assign new codes, and at which point in the production process this occurs.
A document that specifies how variants are handled: which differences in size, colour or season lead to a new code and which do not.
When working with external manufacturers or private label partners: a written agreement on who assigns the code and how it is communicated to the importer or brand.
A technical description of how the code is generated from your own ERP or inventory system, including the source field and any validation rules.
A log of issued codes, so that in case of doubt it can be checked which code was assigned to which product and which production period.

This is not legal advice. This page provides general information about the regulations that this platform covers. We are not familiar with your situation. If you are 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 wrong? Let us know — corrections are given priority.