What is a data carrier under ESPR?

A data carrier is the physical or digital mechanism used to access Digital Product Passport data. Under ESPR, data carriers may include QR codes, data matrix codes, RFID tags, NFC chips, or GS1 Digital Links. The data carrier must be affixed to the product, its packaging, or accompanying documentation, and must remain legible throughout the product's lifetime.

Which data carrier format does ESPR require for the Digital Product Passport?

ESPR does not mandate a single data carrier format. Delegated acts specify the required format for each product category. The GS1 Digital Link standard is widely expected to be adopted as the preferred format because it encodes a unique product identifier that resolves to the DPP data record via a standard URL structure.

How long must a data carrier remain readable on an ESPR product?

The data carrier must remain readable for the entire expected lifetime of the product and for a defined period after the product is placed on the market. The specific durability requirements are set in each delegated act. For products with long lifespans (such as appliances or industrial equipment), this may require durable engraving or embedded RFID rather than printed labels.

Can a data carrier link to a manufacturer's own website for DPP data?

Manufacturers may host DPP data on their own systems, but the data must be accessible via the EU Commission's DPP registry infrastructure once it is operational. The data carrier must resolve to a URL that provides access to all required DPP data fields as specified in the applicable delegated act.

// GLOSSARY

Data Carrier

A data carrier is a physical or digital medium that stores or provides access to a product's Digital Product Passport. Under ESPR, the data carrier must be physically attached to the product or its packaging and must comply with specified technical standards. The most common data carriers for DPPs are QR codes and NFC tags.

Truth Anchor: This definition is based on Regulation (EU) 2024/1781 (ESPR) and related EU legislation. Source: EUR-Lex CELEX:32024R1781

ESPR Requirements for Data Carriers

ESPR Article 9 specifies requirements for data carriers. The data carrier must be permanently attached to the product or its packaging. It must be readable throughout the product's expected lifetime. It must comply with the technical standards specified in the relevant delegated act. For most product categories, the expected standard is GS1 Digital Link (ISO/IEC 18004 for QR codes).

QR Code as Data Carrier

A QR code is a two-dimensional barcode that can store a URL. For ESPR DPPs, the QR code must encode a GS1 Digital Link URL that resolves to the DPP data. The QR code must meet minimum size requirements (typically 2cm × 2cm for consumer products) and must be printed with sufficient contrast for reliable scanning. The QR code must remain scannable throughout the product's expected lifetime — this requires durable printing on packaging and, for long-lived products, a durable label on the product itself.

NFC Tag as Data Carrier

An NFC (Near Field Communication) tag is a passive wireless communication device that can store a URL. NFC tags can be embedded in product labels, packaging, or the product itself. NFC tags are more durable than printed QR codes and can be updated (if the tag is writable). However, NFC tags require an NFC-enabled device to read, which limits accessibility compared to QR codes. The delegated act for each product category will specify whether NFC tags are an acceptable alternative to QR codes.

Data Carrier Placement Requirements

The data carrier must be placed in a location that is accessible to consumers, market surveillance authorities, and recyclers. For consumer products, the data carrier should be visible without disassembly. For products where the data carrier cannot be placed on the product itself (due to size or environmental constraints), it may be placed on the packaging, provided the packaging remains with the product throughout its market lifetime.

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Data Carrier Technologies for ESPR DPPs

A data carrier is a physical medium that stores or encodes data that can be read by a machine. For ESPR Digital Product Passports, the data carrier encodes the product identifier (typically a GS1 Digital Link URI) that links to the DPP data. The main data carrier technologies used for ESPR DPPs are: QR codes (ISO/IEC 18004), Data Matrix codes (ISO/IEC 16022), NFC tags (ISO/IEC 14443), and RFID tags (ISO/IEC 18000 series). The delegated act for each product category will specify which data carrier technologies are acceptable. For consumer products, QR codes are the default choice because they can be scanned by any smartphone without additional hardware. For industrial products, Data Matrix codes or RFID tags may be preferred.

Data Carrier Placement and Durability Requirements

The ESPR data carrier must be placed on the product in a location that is accessible without disassembly and that remains readable throughout the product's lifetime. For products with long lifetimes (construction products, industrial equipment), the data carrier must be applied using a durable method that can withstand the expected environmental conditions — temperature cycling, UV exposure, chemical exposure, and abrasion. The ISO/IEC 15415 standard provides a methodology for grading the print quality of 2D barcodes including QR codes. Manufacturers should test the durability of their data carrier application method under the expected environmental conditions before committing to a production method.