What is GS1 Digital Link and do I need it for the product passport?
A standard to link a barcode to online product information
GS1 Digital Link is a technical way to link a barcode, QR code or other data carrier to a web address containing product information. In practice, this means that a QR code on a tyre does not only contain a number, but a link that points directly to a page with information about that specific product — for example the digital product passport. GS1 Digital Link was developed by GS1, the organisation behind the familiar barcode (GTIN), and is intended to make existing product identification suitable for the web: one scan, one link, and behind it the data that a manufacturer, trader or end-user needs.
What this covers and what it does not
The ESPR itself does not mention GS1 Digital Link by name. Article 11 of the ESPR (Regulation (EU) 2024/1781) describes the requirements for the technical design and operation of the digital product passport in functional terms: there must be a data carrier that is machine-readable, that refers to a unique identification code, and that remains accessible for a certain period. How that link is technically shaped is not laid down in the regulation itself — that will be further specified through delegated acts per product category. GS1 Digital Link is therefore not a legal obligation in itself, but an existing, widely used standard that aligns with what Article 11 and Article 12 require. For the tyre sector this is relevant because the sector has been working with GS1 identification codes for decades; for other product categories, a different technical solution may be chosen, provided it meets the same functional requirements.
What this therefore is not: an obligation that exists separately from the ESPR, and also not a mark of conformity or certification. It is a technical agreement on how a link is structured, comparable to an addressing convention. The question of whether a tyre needs a product passport, and when, is answered by the delegated act for tyres — not by the question of whether GS1 Digital Link is used.
No fixed date yet for a technical standard
There is no fixed date on which GS1 Digital Link, or any other specific technical standard, will be made mandatory for the product passport of tyres. The ESPR leaves the precise technical design of the data carrier to delegated acts per product category, and the one for tyres does not yet exist. According to the ESPR Work Plan 2025-2030, a delegated act for tyres is expected in 2027; the obligation for tyre passports itself is expected around 2029 on that basis, but that date is also not yet fixed. Once the delegated act is published and it becomes clear which technical standard for the data carrier will be prescribed or permitted, this will be updated here. Until then, there is no legal obligation to apply GS1 Digital Link — or anything else — to tyres yet.
What this means in practice
For a tyre importer or wholesaler, the first step is not choosing a technical standard, but getting the underlying product data in order: manufacturer, composition, performance, and the data that the manufacturer or importer already provides. The choice of GS1 Digital Link, or a comparable link between QR code and online data, is an implementation detail typically handled by the platform that compiles the passport and provides the data carrier — this is also how tyrepas.eu fills this part. Those already working with GS1 identification codes (GTINs on packaging or tyres) have a foundation that aligns well with this approach, but do not need to do anything extra as long as the delegated act for tyres has not been published. What is more important is to monitor when that act is published, as it will clarify which data is mandatory and what technical requirements apply to the data carrier. Until then, the main thing is to keep existing product data structured and complete, so that conversion to a passport — regardless of the precise technical standard — can take place later without delay.
Legal basis in Article 11 and Article 12 of the ESPR
Article 11 of the ESPR (Regulation (EU) 2024/1781) establishes that the digital product passport must be accessible via a data carrier that is machine-readable and refers to a unique product identification code. Article 12 describes the framework for that unique product identification code, including identification of the product, the market operator and, where relevant, the production location. Together, these articles form the functional framework to which a technical standard such as GS1 Digital Link can comply, without the regulation specifically prescribing that standard. The specific technical implementation for each product group — including possibly the choice of a specific linking standard — follows from the delegated acts that the European Commission establishes for each product category.
Those already managing tyre data are well advised to record it in a structured and traceable manner per product; this is work that is necessary in any case, regardless of which technical standard is ultimately prescribed for the data carrier.
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 product identification code)
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
GS1 Digital Link is not a legal term from the ESPR — the regulation itself does not prescribe any specific technical standard. What Article 11 of the ESPR (Regulation (EU) 2024/1781) does establish is that the data carrier on the product (usually a QR code) provides access to the product passport, and that the underlying technical setup must be interoperable. GS1 Digital Link is one way to implement this: a web address that is both a valid URL and contains the well-known GS1 identification codes (such as GTIN). This means that a single QR code can be read both by an ordinary smartphone camera and by professional scanning systems.
Ensuring that the QR code leads to the passport
Article 11 requires that the data carrier on or with the product provides access to the product passport. For a company with 10 to 100 employees, this mainly means a practical choice: which type of QR code, where on the tyre, and what structure underlies it. GS1 Digital Link is one possible technical implementation, not the only legally permitted one. More information on placement itself can be found at how do I get the QR code for the product passport on my tyres.
Ensuring that each product has a unique identification code
Article 12 of the ESPR requires a unique identification code per product (or per product model, depending on the delegated act that will apply to tyres). GS1 Digital Link builds on existing GS1 keys such as the GTIN, which many tyre importers and wholesalers already use for logistics and invoicing. That is immediately the practical appeal: no new identification system is needed, the existing product code is reused in the link to the passport. How that identification code is exactly structured can be found at how do I give each product a unique identification code.
Ensuring that the system aligns with what is already in place
For a company that already works with GS1 codes in the ERP or inventory system, the question is mainly whether the existing product codes can be reused without modification in the link structure to the passport. That is precisely what GS1 Digital Link is designed for: the same code, now also readable as a web address. What that means in practice for integration with existing software can be found at can I link the product passport to my ERP or inventory system.
Where things go wrong in practice
QR code that only leads to a product page, not to the passport. Some companies reuse an existing marketing QR code that leads to the webshop or a technical data sheet. That is not the same as a data carrier that provides access to the digital product passport as Article 11 means it — even if relevant information is available on that page.
Confusion between GTIN and the unique identification code from Article 12. A GTIN identifies a product model within the GS1 system, but the ESPR obligation from Article 12 may, depending on the delegated act, require more: a code that is entity-specific, or that operates at a deeper level than the model. Anyone who unreflectively uses the existing GTIN one-to-one as an ESPR identification code risks it not aligning with what the delegated act for tyres ultimately requires.
A single fixed link for an entire product line, while each tyre size has different passport content. Because GS1 Digital Link works well with existing product codes, the temptation is great to create one template URL for a whole range of tyre sizes. Whether that is possible depends on how much data actually differs per size — see can I use the same data for multiple tyre sizes of the same model and how does tyre size relate to the unique identification code.
Technical choice separate from the question of who manages the link in the long term. GS1 Digital Link establishes how the QR code is structured, but says nothing about who keeps the underlying page in the air for ten years. Companies that get the technical side right sometimes forget the agreement about who remains responsible if the company restructures or ceases operations.
Separate implementation per product line without central agreement. When companies have multiple brands or import lines, sometimes a patchwork emerges: one line uses GS1 Digital Link, another uses its own link structure. This works against you practically as soon as maintenance is needed or as soon as the same tyre has multiple passports to deal with — see my product requires multiple product passports, how does that work together.
What you can record
- Which technical standard has been chosen for the data carrier (for example GS1 Digital Link) and why, so that this choice is traceable later.
- How the existing GTIN or other GS1 code relates to the unique identification code that the ESPR requires — are these the same codes or not.
- An overview of which product code belongs to which QR code and which passport, per tyre size and model.
- Agreements with the party that generates the QR codes (yourself, via the manufacturer, or via a platform) on who manages the link structure and adjusts it when changes are made.
- A documented procedure for what happens if a product code changes, a model is phased out, or a new tyre size is added.
- Documentation on the lifespan of the link in relation to the question of how long the passport must remain available, see how long must a product passport remain available.
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.