Data Carrier
Definition
A data carrier is the machine-readable interface attached to a physical product that links it to its Digital Product Passport. Under ESPR Article 9, every product subject to a DPP obligation must carry a data carrier that enables automatic identification and provides access to the product's DPP dataset.
Formats and standards
ESPR does not mandate a single data carrier format, but it requires carriers to be machine-readable and meet specific technical standards. The primary format in current EU technical guidance is:
- QR code — must conform to ISO/IEC 18004 and use GS1 Digital Link URI syntax, enabling the QR code to resolve to a structured data endpoint hosting the DPP
- RFID — radio-frequency identification tags, used where QR codes are impractical (industrial equipment, embedded components)
- NFC — near-field communication, used for products where contactless scanning at short range is preferable
- Datamatrix — 2D barcode format, used in regulated industries (medical devices, pharmaceuticals)
For most consumer products, the QR code using GS1 Digital Link is the expected default. GS1 Digital Link allows the same GS1 identifier (GTIN, serial number, batch/lot) used in existing supply chain systems to serve as the DPP access point — avoiding duplicate identifier systems.
What the data carrier must do
Under ESPR Article 9, the data carrier must:
- Carry or link to the unique identifier of the product (at model, batch, or item level as required by the relevant delegated act)
- Provide access to the DPP data, either by hosting the data directly or by resolving to a data endpoint
- Remain legible throughout the product's entire lifespan and at end of life
- Be accessible to different stakeholders — consumers, recyclers, market surveillance authorities, and customs
The durability requirement for data carriers is significant: a QR code that fades within a year does not meet ESPR requirements for a product with a ten-year expected lifespan.
Battery Regulation precedent
The Battery Regulation (EU 2023/1542) provides the first operational example of EU data carrier requirements. From 18 February 2027, all batteries (including portable batteries) must carry a QR code (per Article 78). However, the full Digital Battery Passport — linking to a complete DPP dataset — is mandatory only for EV, LMT, and industrial batteries with capacity over 2 kWh. Portable batteries must carry the QR code marking but are not required to link to a full DPP. The Battery Regulation's QR code requirements closely follow the ESPR framework and are informing technical standards for DPP data carriers across product categories.
Related terms
- Digital Product Passport (DPP) — what the data carrier links to
- Unique Identifier — the identifier encoded in the data carrier
- DPP Registry — the central system that validates unique identifiers
- ESPR — the regulation mandating data carriers