PLMV-KB-021 · Regulation & Compliance · Reviewed 2026-10-16
GS1 Digital Link, Data Carriers and the DPP
GS1 Digital Link is a GS1 standard that expresses product identifiers such as the GTIN, batch and serial number as a web address. Encoded in a QR Code or Data Matrix, one symbol can be scanned at retail checkout and by smartphones, which makes it a leading candidate data carrier for the EU Digital Product Passport.
Key takeaways
- A GS1 Digital Link URI places GS1 Application Identifiers in a web path, so one code serves supply chain scanning and consumer access.
- Sunrise 2027 is the industry milestone for retail point-of-sale systems to read 2D barcodes, with 1D and 2D codes carried side by side during transition.
- ESPR requires a data carrier and unique identifier for every passport; CEN and CENELEC published harmonised standards for both in 2026.
- The identifier strategy (model, batch or item level) must be decided in PLM and master data before packaging artwork is changed.
What is GS1 Digital Link?
GS1 Digital Link is a syntax for writing GS1 identification keys as a standard web URI. The current GS1 Digital Link Standard for URI syntax is version 1.5.0 (June 2024), complemented by a separate standard for GS1-conformant resolvers (version 1.0.0, February 2024). A typical URI looks like this:
https://id.example.com/01/09506000164908/10/ABC123/21/12345
Each number pair follows the GS1 Application Identifier (AI) logic:
- AI 01: Global Trade Item Number (GTIN), the product or model identifier
- AI 10: batch or lot number
- AI 21: serial number, for item-level identification
- AI 17: expiry date, common in food and healthcare
The domain belongs to the brand or its service provider. A resolver reads the URI and redirects the request to the right destination, such as a product page, safety instructions, recycling guidance or a passport. Because the redirect is managed online, the destination can change without reprinting packaging.
What is Sunrise 2027?
Sunrise 2027 is a GS1 industry milestone for retail point-of-sale systems to accept 2D barcodes alongside the linear EAN/UPC codes used since the 1970s. The two supported retail symbologies are QR Code carrying a GS1 Digital Link URI and GS1 DataMatrix. GS1 describes 2027 as a readiness target and stresses that full 2D capability is not legally mandated by that date. During the transition, many brands print both a linear barcode and a 2D code on the same pack.
For manufacturers, Sunrise 2027 matters because the code that retailers scan at checkout can also become the consumer and regulatory access point for product information. That convergence is what links barcode projects to the Digital Product Passport.
What does ESPR require from DPP data carriers?
The Ecodesign for Sustainable Products Regulation, Regulation (EU) 2024/1781, requires that each product with a passport carries a data carrier linked to a unique product identifier. The product-specific delegated acts decide the granularity (model, batch or item level) and where the carrier goes: on the product, its packaging or accompanying documents.
The technical detail sits in harmonised standards developed by CEN and CENELEC under standardisation request M/604. Six European standards were published in 2026, including EN 18219 on unique identifiers and EN 18220 on data carriers, which covers optical 2D codes, RFID and NFC. Separately, Commission Implementing Regulation (EU) 2026/1778 sets out the DPP registry, which stores identifiers and registration data while the passport content stays with the economic operator or its service provider. See the ESPR overview for the product group timeline.
GS1 positions GTIN plus GS1 Digital Link as one way to meet these identifier and carrier requirements. The regulation itself is technology-neutral, so other ISO/IEC 15459-conformant identifier schemes remain possible.
Comparing data carrier options
| Carrier | Strengths | Limitations |
|---|---|---|
| QR Code with GS1 Digital Link | Readable by smartphones and 2D retail scanners, very low cost | Can be copied, needs print quality control |
| GS1 DataMatrix | Compact, established in healthcare | Fewer consumer apps read it natively |
| NFC tag | No camera needed, supports secure chips for anti-counterfeiting | Unit cost of cents per item (estimate) |
| UHF RFID | Bulk reading in logistics | Limited smartphone support |
The EU battery passport, mandatory from 18 February 2027, is the first large-scale test of these choices. Many companies will combine carriers, for example a printed QR code for consumers and RFID for logistics.
What PLM and master data teams should prepare
The barcode on the pack is the last step of a longer chain. Before artwork changes, decide:
- Identifier granularity. Model-level GTINs suit many consumer goods; batch or serial identifiers suit batteries, textiles with traceability claims and regulated products.
- Ownership of identifiers. GTIN allocation rules should live in PLM or MDM, tied to the product structure and change process.
- Resolver and passport hosting. Choose who operates the domain and resolver, and how long links must persist after a product is discontinued.
- Data sources. Material composition, carbon footprint and repair data typically originate in PLM, while marketing content sits in PIM.
A well-governed identifier strategy lets one 2D code meet checkout, consumer and regulatory needs at the same time.
Frequently asked questions
Does Sunrise 2027 mean linear barcodes disappear?
No. Sunrise 2027 is a readiness milestone for retailers to scan 2D barcodes at checkout. Linear EAN and UPC codes will remain in use for years, and GS1 expects many products to carry both symbols during a transition period. Brands can migrate in stages, starting with packs that have enough space and good print contrast.
Is GS1 Digital Link mandatory for the Digital Product Passport?
No. ESPR is technology-neutral and requires a data carrier linked to a unique identifier that complies with the harmonised standards and the product-specific delegated act. GS1 Digital Link with a GTIN is one widely discussed way to meet that requirement, and it benefits from existing retail infrastructure. Other conformant identifier schemes can also qualify.
Can one QR code serve consumers, retailers and regulators?
Yes, that is the design goal of GS1 Digital Link. A resolver can return different content depending on the request, for example a consumer page, a retail product record or a passport view for authorities. The passport system behind the link controls access rights for restricted data, so the printed code itself carries no confidential information.
Sources
- GS1 Digital Link standard (GS1)
- GS1 US: Sunrise 2027
- Regulation (EU) 2024/1781 on ecodesign for sustainable products (EUR-Lex)
- Commission Implementing Regulation (EU) 2026/1778 on the DPP registry (EUR-Lex)
Reviewed 16 October 2026 by the PLM Vendors editorial team. Regulatory dates and vendor details change; check the sources for the latest position.