What is GS1 Digital Link and do I need it for the product passport?
GS1 Digital Link links a product code to a web address
GS1 Digital Link is a technical standard from GS1 — the organisation behind the familiar barcodes and GTIN numbers — that allows a single QR code or barcode to do two things at once: identify a product and direct to a specific web page. A shop till reads the code as a product code, while a consumer with a smartphone can scan the same code and go directly to, for example, care instructions, information about origin, or the digital product passport. Whether this precise format will become mandatory for the textile passport is not yet fixed: the ESPR (Regulation (EU) 2024/1781) sets out in Article 11 that a data carrier must be used and that it must meet certain technical requirements, but the exact design will be worked out through separate technical specifications. GS1 Digital Link is currently one of the existing standards that aligns well with what Article 11 and Article 12 describe, but the text itself does not name GS1 specifically.
For whom this is relevant, and for whom it is not yet
This standard is particularly relevant for companies that already work with GS1 identification codes, such as GTINs on the familiar EAN barcodes used in retail. For clothing brands and importers who already run their collections through the supply chain using such codes, GS1 Digital Link is a logical extension: the same code, an additional layer of information. For companies that do not use GS1 codes, or that still need to establish whether their current article numbering aligns with them, this is less directly applicable — they will first need to determine what identification system they already use.
It is important to distinguish between two things that are easily confused. Article 11 of the ESPR makes a data carrier mandatory for the product passport — in practice almost certainly a QR code. That is the obligation. GS1 Digital Link is not the obligation itself, but one possible technical implementation of how that QR code is structured. Other standards also exist for combining identification and web links, and which standard will ultimately be prescribed — or whether there will be room for multiple standards alongside each other — is not yet known from the texts published so far.
No fixed date yet for the technical design
No date is known for when a specific format such as GS1 Digital Link will become mandatory for the textile passport. The ESPR itself establishes the general technical design requirements in Article 11, but the concrete implementation — including any naming of standards — still needs to be worked out. For textiles specifically, the underlying delegated act that activates the product passport for clothing and textiles is expected in 2027 according to the European Commission's work plan for 2025–2030, with clothing that is eighty per cent or more textile fibres as the first category. Until that act is published, there is no binding technical specification that a data carrier must meet. As soon as that changes, it will be updated here.
What this means for your approach
The first step is to establish whether GS1 identification codes, such as GTINs on existing EAN barcodes, are already being used. Those who already use them have a head start: the basic infrastructure for something like GS1 Digital Link is then largely in place. Those who do not need take no action now — there is no obligation to introduce GS1 codes in advance of a standard that has not yet been fixed.
The second step is: do not anticipate a format that is not yet established. Major investments in a specific technical implementation cannot be justified at this moment by an established obligation — the text of Article 11 leaves the precise implementation open. What is useful, however, is to review GS1's documentation on Digital Link to get an idea of the direction in which this type of standards is moving, without basing a decision on it yet.
The third step only comes when the technical specifications for the textile passport are published. At that point, it will become clear which data carrier standard applies, and the QR code for the passport can be set up accordingly. That is also the moment when a platform such as texpas.eu supplies the data carrier in accordance with the standard then in force — including GS1 Digital Link, if that proves to be the chosen direction.
Where this follows from: Article 11 and Article 12 of the ESPR
Article 11 of the ESPR (Regulation (EU) 2024/1781) describes the technical design and functioning of the digital product passport, including the requirement for a data carrier to make the passport accessible. Article 12 governs the unique identification code associated with the passport. Both articles describe the functional requirements — a readable link between product and online information, and an identification code that is unique — without naming a specific existing standard such as GS1 Digital Link. The further technical implementation of these requirements follows from regulations to be published later.
Those already working with GS1 codes can keep that information in order and monitor developments around the technical specifications; those who do not do so do not need to take action on this at this time. Once the technical standard for the data carrier of the textile passport is established, this will be supplemented here.
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 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
GS1 Digital Link is not a separate legal requirement with its own article number, but a technical standard that aligns with what the ESPR does require: a data carrier on the product that refers to the product passport, and a unique identification code that links the passport and the product to each other. GS1 Digital Link is a way to structure a barcode or QR code so that one and the same code can be read both as a traditional barcode (for example at the checkout) and, scanned with a phone camera, links through to a web page — in this case the product passport. For companies that work with GS1 numbers (GTIN, EAN) this is in practice the most straightforward way to comply with Article 11 and Article 12 of the ESPR without running two separate systems side by side.
The data carrier must be readable and uniform
Article 11 of the ESPR (Regulation (EU) 2024/1781) describes that the product passport must be accessible via a data carrier on or attached to the product. For a company with 10 to 100 employees this means in practice that a choice must be made about the format of that carrier — usually a QR code — and about how that code is structured. If you already work with GS1 barcodes for logistics and sales, you can expand that structure with GS1 Digital Link instead of setting up a completely new coding system alongside the existing one. More about the physical placement of that code on the garment is described on the page about how the QR code for the product passport ends up on clothing and textiles.
The unique identification code must align with existing product numbers
Article 12 of the ESPR calls for a unique identification code per product. For companies that already work with GTINs, it makes sense to use that existing product code as a basis instead of introducing an entirely new, random code. GS1 Digital Link in this context is the format that converts that GTIN into a web address — the code that appears on the clothing label is then both the GS1 product number and the reference to the passport. How that identification code is precisely constructed and what it involves is explained on the page about how you give each product a unique identification code.
One code must be able to serve multiple purposes
For a clothing brand or importer it is practically relevant that one QR code must not only link to the product passport, but in practice is also used for marketing, warranty information or a take-back programme. GS1 Digital Link is structured so that one code with different parameters can refer to different destinations, depending on who or what scans it. This is relevant for companies where the product may fall under multiple regulations — for example when a garment is subject to both textile rules and other product requirements. How that interaction works is described on the page about multiple product passports for one product.
Where things go wrong in practice
A common situation is that a company has worked with GS1 barcodes for its own logistics for years, but has a completely separate QR system built for the product passport by an IT supplier. The result is two parallel numbering systems that do not align with each other, with double administration and a greater chance of errors with new collections.
Another situation arises when the QR code does refer to the passport, but is not structured according to the GS1 Digital Link format. The code then works fine for a consumer who scans it, but does not align with the way other parties in the chain — for example an importer or a recycler — automatically read GS1 data. As a result, information that already exists must be entered manually again.
Also challenging: a company assigns a separate GTIN to every colour and size (which is standard GS1 practice), but sets up the product passport at collection level rather than at variant level. During an inspection based on a scanned code, the data does not precisely match the scanned article. What must or must not be kept separate per size and colour is explained on the page on seasonal collections and variants.
A fourth situation: the GTIN is used internally, but the link to the passport is maintained manually in a separate file, outside the ERP or inventory system. With each new collection or price change, there is a risk that the link will not be updated. Whether and how that link can be automated is described on the page on linking to your own ERP or inventory system.
A fifth, less visible situation: a company uses GS1 Digital Link codes correctly, but has no visibility into who manages the underlying web page after the passport is published. When an error in the data is discovered later, it is unclear who has the authority to modify the content behind the code.
What you can record
- Overview of existing GS1 numbers: which GTINs are already in use per product, colour and size, and whether this structure is reused for the product passport.
- Choice of data carrier format: an internal note documenting whether GS1 Digital Link or another format is chosen, and why.
- Link between product code and passport URL: a document or system setting documenting how the identification code automatically refers to the correct passport page, including who manages this link.
- Responsible party for changes: an agreement on who is authorised to modify data behind a published code, and how that process works — see also the page on discovering an error in a published product passport.
- Agreements with the IT or platform provider: documenting which format will be supplied, who manages the QR code technology, and how new product variants are added without changing existing codes.
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.