QR Code, NFC or RFID: DPP Data Carriers Compared
Data carriers for the Digital Product Passport: what EU law requires, how QR code, NFC and RFID differ, and how a GS1 Digital Link encodes the identifier.
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This article compares the three technologies and explains what the carrier should contain.
What the law says about data carriers
ESPR, Regulation (EU) 2024/1781. Article 2 defines the data carrier as a linear barcode symbol, a two-dimensional symbol or other automatic identification data capture medium that can be read by a device. Article 9 leaves it to the delegated act to specify which data carriers are to be used and where they are placed. Article 10 requires that the passport is connected through a data carrier to a persistent unique product identifier, and that the carrier is physically present on the product, its packaging or the documentation accompanying it, as the delegated act specifies.
Batteries Regulation (EU) 2023/1542. The battery passport is accessible through a QR code. The code must be in high contrast to the background and of a size that common QR readers can read easily. This applies from 18 February 2027.
Toy Safety Regulation (EU) 2025/2509. The data carrier must be physically on the toy or on a label attached to it, and clearly visible to the consumer before any purchase, including in distance sales. The passport applies from 1 August 2030.
Detergents Regulation (EU) 2026/405. The data carrier must be indelible and machine-readable and accompanied by a statement inviting the user to scan it for more comprehensive information on the product. The passport applies from 23 September 2029.
Harmonised standard. EN 18220, "Digital product passport: data carriers", is one of the six standards cited in the Official Journal in July 2026. It sets the technical details for carriers in the DPP system. The standard itself is sold through national standards bodies; obtain it before you finalise a label design.
One more duty: a digital copy for sellers
The physical carrier is not enough for online sales. Under Article 10 of the ESPR, the economic operator must provide dealers and providers of online marketplaces with a digital copy of the data carrier or the unique product identifier, free of charge and within five working days of a request. Dealers in turn must make sure customers can access the passport, also when selling at a distance. In practice this means your product data feed should be able to carry the passport link.
QR code, NFC and RFID in comparison
The comparison below describes general properties of the technologies. It is not a statement about which carrier a future delegated act will permit.
| Aspect | QR code (printed 2D code) | NFC tag | UHF RFID tag |
|---|---|---|---|
| How it is read | Camera, line of sight | Close contact, a few centimetres | Radio, at a distance, no line of sight |
| Reader | Any current smartphone camera | Most current smartphones | Dedicated reader |
| Cost per unit | Print cost only | Tag plus integration | Tag plus integration |
| Typical strength | Universal access for consumers | Works where printing is unwanted or wears off | Bulk reading in logistics and stores |
| Typical weakness | Can be damaged, soiled or removed | Consumers must know where to tap | Consumers cannot read it |
| Fits best for | Public access to the passport | Durable goods, premium items, hidden placement | Internal processes alongside a consumer-readable carrier |
Three practical conclusions follow.
- A printed 2D code is the baseline. It is the only carrier every consumer, repairer and inspector can read without extra equipment, and it is what the adopted regulations name.
- NFC and RFID are complements. They solve specific problems, such as durability on a product that is washed or worn, or fast stock handling. Whether they may replace a printed code depends on the legal act.
- Durability is part of compliance. The passport must stay reachable for the period the legal act sets. A code on packaging that is thrown away at purchase does not help a repairer years later, which is why the acts specify placement.
What goes into the data carrier
The carrier should hold as little as possible: an identifier that resolves to the passport. Product data lives in the passport, where it can be corrected and updated without reprinting.
The ESPR defines the unique product identifier as a unique string of characters for the identification of a product that also enables a web link to the passport. The identifier and the link therefore belong together. A common way to combine them is a web address that contains the identifier in a standard structure.
Example: the GS1 Digital Link
GS1, the organisation behind the barcodes used in retail, publishes the GS1 Digital Link URI syntax. It expresses GS1 identifiers, such as the Global Trade Item Number (GTIN), as a web address. Release 1.7.0 was ratified in August 2026. The basic structure for a product is:
https://example.com/01/09520123456788/10/ABC123/21/12345
| Part | Meaning |
|---|---|
https://example.com |
Your own domain, or id.gs1.org in the canonical form |
/01/09520123456788 |
Application identifier 01: the GTIN, always padded to 14 digits |
/10/ABC123 |
Application identifier 10: batch or lot (optional) |
/21/12345 |
Application identifier 21: serial number (optional) |
A few rules from the standard matter in practice:
- The GTIN is the primary key and always comes first.
- Qualifiers are optional, but their order is fixed: consumer product variant (22), then batch or lot (10), then serial number (21).
- Batch and serial values may have up to 20 characters. Characters with a special meaning in web addresses must be percent-encoded.
- Further attributes, such as an expiry date, go into the query string, not the path.
- HTTPS is the recommended scheme. A custom domain is allowed.
The same structure covers the three passport levels: GTIN alone for a model, GTIN plus batch for a lot, GTIN plus serial number for an item. You can build and check such a link with our GS1 Digital Link builder, which also validates the GTIN check digit.
Two cautions. First, the legal texts reviewed for this article do not prescribe GS1; they require standardised, interoperable identifiers, and the battery rules refer to the ISO/IEC 15459 series. Check the delegated act and EN 18219 for your product group. Second, a Digital Link is only the address. It becomes part of a passport when the address resolves to passport data and the identifier is registered.
Practical questions for label design
- Placement. On the product where the act requires it. Think about where a repairer or recycler will look years later.
- Size and contrast. A code that prints cleanly on a carton may fail on a woven label or curved surface. Test with several phones.
- Quiet zone. 2D codes need a clear margin around them.
- Coexistence. Many products carry a retail barcode already. Decide whether one 2D code can serve checkout and passport, or whether two codes are needed, and label them so users know which to scan.
- Domain longevity. The web address in a printed code cannot be changed after printing. Use a domain you control for the whole availability period, and keep the link structure stable.
- Fallback. Plan what a user sees if the product is not found, the network is down or the passport has restricted data.
Common mistakes
- Encoding product data directly in the code instead of an identifier.
- Using a marketing short-link service whose addresses can expire.
- Printing item-level codes before knowing whether the act requires model, batch or item level.
- Treating the QR code as the passport. It is the entry point; the obligations sit in the data behind it. See what data goes into a DPP.
For the broader picture, read what the Digital Product Passport is.
Checklist: data carrier decisions
- You know which legal act governs the carrier for your product group and whether it is adopted.
- You have chosen an identifier scheme based on a recognised standard.
- The web address in the carrier uses a domain you will control long term.
- The carrier contains an identifier or link only, no product data.
- Placement and durability match the product's lifetime.
- Print quality has been tested on the real material.
- Your product feed can pass the link or code to dealers and marketplaces within five working days.
Sources
- Regulation (EU) 2024/1781 (ESPR), Articles 2, 9 and 10, EUR-Lex
- Regulation (EU) 2023/1542 (Batteries), Articles 13 and 77, Annex VI, EUR-Lex
- GS1 Digital Link Standard: URI Syntax
- CEN and CENELEC: standards for the Digital Product Passport
- Implementing Decision (EU) 2026/1736 on harmonised DPP standards, EUR-Lex
- Regulation (EU) 2025/2509 (Toy Safety), EUR-Lex
This article is general information, not legal advice. Status checked on 11 November 2026.
FAQ
Does the Digital Product Passport require a QR code?
For batteries, yes: the Batteries Regulation names the QR code. Under the ESPR, the delegated act for each product group specifies the data carrier; the definition also allows other machine-readable carriers. In the Commission's descriptions the QR code is the standard example.
Can I use NFC or RFID instead of a QR code?
Only where the applicable legal act and the harmonised standard on data carriers allow it for your product group. Even then, many companies add them alongside a printed code, because a printed code needs no special hardware to read.
What must the data carrier link to?
To a persistent unique product identifier that leads to the passport. The carrier holds the identifier or link, not the product data itself.
Is a GS1 Digital Link mandatory for the DPP?
No legal text reviewed for this article mandates GS1 specifically. The ESPR requires identifiers based on recognised standards, and the GS1 Digital Link is one widely used way to express a GTIN as a web address.
Where does the data carrier have to be placed?
On the product, its packaging or the accompanying documentation, as the legal act for the product group specifies. For toys it must be on the toy or an attached label and visible before purchase.