How do I give each product a unique identification code?

What you concretely must do

What is expected of you

Each product receives its own unique code

Article 12 of the ESPR (Regulation (EU) 2024/1781) requires that a digital product passport receives a unique identification code. For a mattress manufacturer, this means: not one code for an entire product line, but one code per product placed on the market. In practice, this amounts to an extension of what many companies already do with internal article numbers or batch codes, but slightly more precise — the code must distinguish the individual product (or, depending on how the product rules stipulate this, the production unit) from all others, including within the same mattress line and the same format.

For a company with 10 to 100 employees, this usually does not require setting up a new system, but rather adapting the existing order system or production registration so that each mattress receives a code when leaving the factory that can be linked to one passport. Those already working with GS1 numbers will recognise the principle; those who do not may ask themselves what GS1 Digital Link exactly is and whether that is necessary for the product passport.

The code must enable the link with the passport

Article 11 of the ESPR describes the technical requirements for the product passport, including that the identification code and the data carrier (usually a QR code) must together ensure that the passport of a specific product is actually found with that product. This is not only an IT matter but also a logistical one: the code must be fixed at the time of production or packaging, before the QR code is applied to the product. Companies that assign a code only afterwards, at shipment or sale, risk that passport and product no longer remain in sync. See also the question how the QR code for the product passport is applied to mattresses.

The code follows the product throughout its entire lifecycle

A unique identification code is not a one-time label, but a reference that must remain intact as long as the product exists — and therefore also as long as the passport must be available. This directly affects the question how long a product passport must remain available. For a manufacturer, this means that the code may not be reused for another product, even after years, and that the administration linking product code and passport must not be lost — even during a system change, takeover, or cessation of one of the companies in the chain. See also on this what happens to the product passport if a company stops operating.

The code must comply with the European register

Article 12 is linked to the obligation to report passport data (including the identification code) to the central register. Those who wonder what the register of digital product passports exactly is and what must be entered in it, should view this in combination with the identification code: the register recognises passports via that code, so an error or duplicate code there creates problems further down the chain.

Where things go wrong in practice

One code per product line instead of per product. A manufacturer reuses the existing article number of a mattress model as the "unique identification code" for the passport. This works until ten identical mattresses with ten different passports are needed — and then the code proves not to be unique enough.

Code is assigned only after production. In companies where administration and the production floor are not well aligned, the identification code is sometimes entered in the system afterwards, for example during invoicing. The product is already in the warehouse or on its way to the store, without the QR code matching what is stated in the passport.

Customisation without a clear code structure. For custom-made mattresses, where dimensions, firmness or stitching differ per customer, there is often no clear rule for how each variant receives its own code. This leads to confusion between what constitutes one product and what is an option within a product. See the approach for this at the product passport for bespoke mattresses.

No link between ERP system and passport code. Some companies enter the identification code manually, separate from the existing order system. This works with small volumes, but becomes error-prone once production scales up. The question whether the product passport can be linked to your own ERP or inventory system is more relevant than is often thought.

QR code becomes detached from the code in the passport. When a label comes loose or wears out and a new label with a new number is applied without consultation, a mismatch arises between the physical product and the digital passport. See on this subject what to do if the QR code of the mattress is damaged and, for stock that has already left the factory without a code, whether a QR code can still be applied to an already produced mattress.

What you can record

• An overview of how the unique identification code is constructed (for example on the basis of an existing GS1 number, supplemented with a production or batch sequence number).
• The point in the production process at which the code is assigned, and who is responsible for it.
• The link between the identification code, the internal order system or ERP, and the passport — including an agreement on what happens in the event of a system change.
• A procedure for bespoke products: how a variant receives its own code without the baseline and the option becoming confused with each other.
• A backup arrangement for the administration in which product code and passport are linked to each other, also relevant to the question what happens to passport data if the hosting party stops.
• An internal instruction for the production floor on applying the QR code in combination with the assigned code, so that code and label are never created separately from each other.