How do I assign a unique identification code to each product?

Each product receives its own code, linked to the QR code

The unique identification code is the identifier by which one specific product (or a specific batch) is inextricably linked to its digital product passport. Article 12 of the ESPR (Regulation (EU) 2024/1781) stipulates that a product falling under a digital product passport must be provided with a unique identification code, and where relevant also with an identification code for the economic operator and for the production facility. This code ensures that an inspector, a subsequent actor in the supply chain, or the end-user can always access the correct, up-to-date passport data via the data carrier on the product — the QR code, regulated in Article 11 — and not those of another model or batch.

For the tyre, not for the existing DOT number

This identification obligation applies to products falling within a product group for which the European Commission has established a digital product passport through a delegated act. This is not yet the case for tyres: no delegated act has been published that specifically designates tyres as a product group. The unique identification code from Article 12 therefore only becomes relevant once that act is in place and indicates which products within the tyre sector fall under it. It is also important to clarify what the code does not replace: existing identification means such as the DOT number, type-approval numbers or internal batch numbers continue to exist alongside the new code. The ESPR identification code is an additional identifier specifically intended to establish the link with the digital passport, not a replacement for previous markings on the tyre itself.

No fixed date yet, but a clear direction

When the identification obligation for tyres will concretely take effect is not yet established. According to the ESPR work plan 2025-2030, a delegated act for this product group is expected in 2027; actual implementation would follow thereafter, with 2029 as a provisional target. As long as that act has not been published, there is no obligation for tyres to have a unique identification code in the sense of Article 12. What is established is the framework itself: the ESPR has been in force since 2024 and Article 12 already sets out the general rule for all product groups that will be designated later. Once the delegated act for tyres has been published, with the precise date and details for this sector, this will be updated here.

How to approach the structure of the code in practice

Despite the fact that the obligation for tyres is not yet established, it is worthwhile to start thinking now about the structure of such a code, especially because an importer or wholesaler usually already has most of the data in-house. The order that makes sense in this respect is as follows: first, draw up an overview of the product types and models that could later fall under the passport, and of the identification data already associated with them, such as DOT code, batch number and production facility. Then determine which of the three levels from Article 12 are relevant for your own situation: the code of the product itself, the code of the economic operator providing the passport, and possibly the code of the production facility. Next, it is important that this code is recorded in a way that aligns with internationally recognised identification systems, as Article 12 takes as its starting point, so that the code is not only useful internally but can also be recognised and looked up by other actors in the supply chain and by supervisory authorities. Finally, the link with the data carrier is the step that makes it practical: the unique code must ultimately be retrievable via the QR code on or near the product, as Article 11 stipulates for the digital product passport as a whole. Those who bring structure to this now — for example by consistently managing existing batch and batch numbers — will not have to start from scratch when the delegated act is published.

Where that is stated: Article 12 and Article 11 of the ESPR

The obligation to use a unique product identifier derives from Article 12 of the ESPR (Regulation (EU) 2024/1781), which governs the identifier for the product, the economic operator and the manufacturing facility. The linking of that identifier to the digital product passport via a physical data carrier on the product derives from Article 11 of the same regulation, which establishes the technical design and functioning of the passport. Together, both articles form the framework; the product-specific requirements for tyres will follow only with the delegated act for this product group.

Whoever is already dealing with tyre passports should best start by putting their own product, batch and location data in order, and keep an eye on the publication of the delegated act for tyres to see when and how the unique product identifier for this sector will be concretely implemented.

What this is based on

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

What you must do concretely

What is expected of you

Each product receives its own, unique code

Article 12 of the ESPR (Regulation (EU) 2024/1781) stipulates that a product falling within the scope of the digital product passport must receive a unique identification code. For a tyre, this means that a code will be assigned to that specific product (or that specific product group, depending on how the delegated act for tyres specifies this) to distinguish it from every other product. In practice, for a company with 10 to 100 employees, this means that the method by which article numbers, batch numbers or internal SKUs are currently assigned must be reviewed: does that system align with what will later need to serve as the unique identification code, or is an additional layer required on top of the existing numbering?

The code must be linkable to the correct passport

A unique identification code is only valuable if it unambiguously refers to one digital product passport. Article 11 of the ESPR describes the technical requirements for the passport itself, including the way in which the data carrier — presumed to be a QR code for tyres — and the underlying data are linked together. For an importer or wholesaler, this means that the administration in which product data is maintained (ERP, inventory system, or a separate Excel file) must be able to establish a conclusive link between the unique code on the product and the passport that belongs to it. Those who already do this with batch codes or internal references may ask themselves whether the product passport can be linked to their own ERP or inventory system.

The code must remain consistent and traceable, even after sale

A unique identification code is not a one-time label that loses its function after sale. As long as the passport must remain available, the code must also remain traceable to the correct passport. This touches on the question how long a product passport must remain available, and on what happens to that traceability when an importer changes role, an assortment is discontinued, or a business ceases operations — a question that is addressed separately on the page about what happens to the product passport if a company ceases operations.

The code must align with existing identification systems

Article 12 allows for the use of existing identification systems, provided they meet the requirements. For the tyre sector, it is logical that GS1-like systems play a role, as wholesalers and retailers often already use them for logistics and invoicing. A company already using GS1 numbering may ask itself whether that system can be reused without modification, or whether an additional layer is needed — a question that is addressed on the page about what GS1 Digital Link is and whether it is necessary for the product passport.

Where things go wrong in practice

One code for an entire product line, rather than per variant. An importer assigns one article code to a tyre model, while multiple sizes, load indices and speed ratings are sold under that designation. Once a unique identification code must be assigned per product subject to the passport requirement, confusion arises as to which code belongs to which physical tyre.

Confusion between tyre size and identification code. Some companies (still) assume that the tyre size itself is sufficiently distinctive to serve as identification. However, size and identification code are not automatically the same concept, and the distinction between them is explained on the page about how tyre size relates to the unique identification code.

Batch numbers that do not align with the passport. Manufacturing processes often already assign a batch or production code, without any consideration of a digital passport. When that batch code subsequently has to serve as a unique identification code, it often turns out that the same code was accidentally assigned to multiple batches, or that its registration is incomplete.

Reuse of data without considering the code. A manufacturer may want to use the same technical data for efficiency purposes across a series of comparable tyre sizes of the same model. This can be a workable approach for the content of the passport, but the unique identification code must be correct for each product or product group. This trade-off is explained further on the page about whether the same data can be used for multiple tyre sizes of the same model.

No link between QR code and underlying identification. A QR code is applied to the tyre, but the link between that code and the unique identification code in the underlying systems is not properly established. During an inspection or when a fleet manager lodges a complaint, it turns out that nobody can reconstruct which passport belonged to which physical tyre. How that QR code ends up on the product is described on the page about how the QR code for the product passport is applied to tyres.

What you can record

An overview of which internal numbering system (article code, batch code, GS1 number) serves as the basis for the unique identification code per tyre type.
A document setting out how the unique identification code relates to existing tyre size designations, so as to prevent confusion between these two concepts.
A record of which product groups or variants share data, and on what basis that sharing takes place.
A technical description of the link between the data carrier on the product and the underlying identification code in your own system or ERP package.
A note on the agreements with suppliers or manufacturers regarding who assigns the unique identification code and at what point in the production process this takes place.
An overview of how the identification code is supplied or registered in the European digital product passport register, as soon as that becomes applicable.

This is not legal advice. This page provides general information about the legislation that this platform concerns. We do not know 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 incorrect? Let us know — corrections are given priority.