Is GS1 Mandatory? ESPR Technology Neutrality
A belief has grown around the Digital Product Passport that it requires using the GS1 standard. It is a misconception worth clearing up. EU law is more open on this point than is commonly assumed.
The short answer: no
GS1 is not formally mandatory. ESPR (Regulation 2024/1781) does not name GS1 or GS1 Digital Link as the only permitted solution. It does require a product to have a unique identifier and a data carrier that leads to a machine-readable record.
In other words, the law defines the functions that must be met, not a specific brand or technology. That is an important difference, because your freedom to choose a solution depends on it.
What ESPR actually says
The ESPR approach is often described as technology neutrality. It means the regulation sets requirements about the outcome — unambiguous identification and access to data — but does not mandate a single technical path.
That lets different industries and different manufacturers match a solution to their needs. One system would not have to fit every product, from batteries to textiles.
Why GS1 is a common choice
If GS1 is not mandatory, where does its popularity come from? The reason is practical. Many companies already use GTIN numbers and barcodes in retail, so extending them for DPP purposes is a natural step.
GS1 also offers recognised, global rules for encoding identifiers, which makes cooperation with trading partners and external systems easier. For many manufacturers it is the most convenient, proven option — but convenience is not the same as obligation.
When GS1 may turn out to be needed
Although the law does not mandate GS1, in practice situations may arise where using it is advisable. Trading partners, retail chains or a specific sector's requirements may expect identifiers in a recognised standard.
So it is worth separating two questions: what ESPR itself requires, and what your market and counterparties expect. The first is open, the second can be more specific.
What the alternatives are
Technology neutrality means other identification schemes are also allowed, as long as they meet the required functions. The key is that the identifier is unique and stable, and the carrier durable and readable.
Whatever approach you choose, the data record must be machine-readable and available under the rules of layered access. That is a functional requirement, not a requirement for a specific technology. More on identifiers themselves in GS1 Digital Link and GTIN.
What to watch when choosing
When picking a solution, a few questions help guide you:
- will the identifiers be unique and stable over time,
- will the carrier stay readable throughout the service life,
- can the data be maintained, updated and shared in a layered way,
- what do your trading partners and target markets expect.
The answers to these questions matter more than the name of the standard. We cover the difference between carrier and data in DPP vs QR code.
Neutrality versus interoperability
Technology neutrality does not mean 'anything goes'. Even without an obligation to use GS1, it is worth ensuring interoperability — that data can be exchanged and reused across different systems.
Recognised, widely used identifier schemes simply make this cooperation easier. Choosing your own non-standard solution is allowed, but it can complicate integration with partners.
Common myths about GS1 and DPP
A few misconceptions circulate around this topic. The first is the belief that you cannot meet DPP requirements without GS1 — which is not true.
The second is assuming that choosing GS1 automatically 'handles' compliance. The standard helps with identification, but it does not remove the need to prepare complete, correct data in the record.
Key takeaways
- GS1 is not formally mandatory under ESPR.
- ESPR requires a unique identifier and a carrier leading to a record — not a specific technology.
- GS1 is popular because it is practical and familiar from retail, but that is not an obligation.
- Partner or sector requirements may, in practice, push you toward recognised standards.
- The functions are what count: uniqueness, carrier durability and layered data access.
See how CyfroPass lets you build and publish a Digital Product Passport without writing code. Visit cyfropass.pl and start with your first product.