No adopted EU text requires a GTIN for a Digital Product Passport. Annex III of the ESPR lists the GTIN, “or equivalent”, as one data element a product act may choose. Every passport must link to a persistent unique product identifier. A product act can also require unique operator identifiers for businesses and unique facility identifiers for sites.
Is a GTIN mandatory for a DPP?
Not under any adopted text. Annex III of the Ecodesign for Sustainable Products Regulation (ESPR), Regulation (EU) 2024/1781, lists the GTIN, the number behind most retail barcodes, at point (c), “or equivalent”. Each product’s delegated act picks which Annex III elements “are to or can be included”, and none has been adopted. The unique product identifier is a separate point, (b), so a GTIN does not replace it. The battery passport does not ask for a GTIN either: Article 77(3) of Regulation (EU) 2023/1542 requires an identifier that meets ISO/IEC 15459 or an equivalent.
What are the three DPP identifiers?
Article 2 of the ESPR defines each one as a unique string of characters:
| Identifier | What it identifies | Status in the ESPR |
|---|---|---|
| Unique product identifier | The product, at the model, batch or item level the act sets, with a web link to the passport | Required, Article 10(1)(a) |
| Unique operator identifier | A business in the value chain, such as the manufacturer or a supplier | An act may require it, Annex III (g), (h), (k) |
| Unique facility identifier | A location or building in the value chain | An act may require it, Annex III (i) |
A data carrier, such as a QR code, connects the product to its identifier. The answer on what a DPP must include covers the other Annex III data.
Which standard do the identifiers follow?
The ESPR names the ISO/IEC 15459 series, parts 1 to 6, in Annex III. Articles 10(1)(c) and 12(1) accept those or equivalent standards until harmonised standards are published. Since 15 July 2026, Implementing Decision (EU) 2026/1736 has cited EN 18219:2026 on unique identifiers. Following it gives a presumption of conformity with Articles 10 and 11, as far as it covers them. Whether EN 18219 now takes over from ISO/IEC 15459 is unsettled, and the DPP standards answer lists the full set. No draft of the rules on identifier issuers and self-issued identifiers, allowed by Article 12(4), had been published by 18 October 2026.
What if a supplier has no operator or facility identifier?
The business creating the passport requests one on the supplier’s behalf. Article 12(2) and (3) require it to confirm first that none exists, then pass on the details once issued.
How does the EU registry handle the product identifier?
As an https:// web address, according to version 1.03 of the Commission’s registry user guide. After upload, the registry returns a different number, the registration identifier, which customs will ask for once the registry is linked to their systems, due by 6 August 2030. The registry went live on 20 July 2026, but no passport can be registered yet.
Sources: ESPR, Regulation (EU) 2024/1781, Implementing Decision (EU) 2026/1736, Regulation (EU) 2023/1542, DPP Registry user guide, v1.03
Before a carrier is printed, GreenSutra’s DPP consulting settles which identifiers a product needs and at what level. The DPP guide compares the rules law by law.