What is GS1 Digital Link and do I need it for the battery passport?

What you need to do concretely

What is expected of you

GS1 Digital Link is not a separate legal requirement with its own article number, but a technical standard that enables a QR code to do two things simultaneously: identify a product and direct to a web page. For the battery passport, this is relevant because Article 78 of Regulation (EU) 2023/1542 (batteries regulation) prescribes that the passport must be accessible via a data carrier on the battery, and GS1 Digital Link is currently the most common way to technically implement this link.

The QR code must lead to the passport and identify the product

A QR code that contains only a long, meaningless web address technically meets the requirement that the passport is accessible. But GS1 Digital Link makes that same QR code also a readable identification carrier: it incorporates a product code (often a GTIN or comparable identification) that scanners, ERP systems and supervisory authorities recognise. For a company with 10 to 100 employees, this means that the choice of a data carrier is not only an IT question, but also affects how batteries are identified internally and externally. Anyone who already has a GS1 membership and GTINs running can often extend that structure to the passport. Anyone who does not must choose between their own identification system and alignment with an existing standard. More on the identification itself can be found under how do I give each battery a unique identification?.

The code must remain readable with ordinary scanning equipment

Article 78 expects the passport to be consulted with generally available equipment — not with a special scanner that only stands at the manufacturer's counter. GS1 Digital Link is designed so that an ordinary smartphone camera can read the code and forward it directly to a web page, without a separate app. For a company, this means that the choice of a QR format is also a user experience: a technician, recycler or inspector must be able to scan the code without prior knowledge of the system behind it. Practical choices about the physical placement and format of the code are described under how does the QR code for the battery passport end up on the battery?.

The data carrier must comply with the labelling requirements

Article 13 of Regulation (EU) 2023/1542 (batteries regulation) sets out which labels and markings must be on a battery, separate from the passport itself — think of chemical composition, capacity and other characteristics. The QR code for the passport comes in practice next to or between these. A company redesigning its labelling for the batteries regulation would be well advised to combine these two obligations in one design, rather than applying them separately to the product. Which information is precisely required as a separate label is described under which labels and markings must be on a battery?.

The link must work with the systems that actually host and manage the passport

GS1 Digital Link determines the form of the code, but not where the data is stored or who manages it. This remains a separate question: who ensures that the web page behind the QR code remains accessible for ten years, and who is responsible if the company changes ownership or ceases operations. For a mid-sized company, it is important that the choice of a data carrier standard is not separate from the choice of a hosting partner: both must align. See on this where is the battery passport data stored online and who manages it.

Where things go wrong in practice

An importer has the QR code printed by the label supplier, without anyone checking whether the underlying link has a valid GS1 Digital Link structure or is just a plain URL. This often works fine until a system further down the chain actually tries to recognise the code as GS1 identification, and fails to do so.

A company uses a different product code for the passport than for its own inventory management, because the two systems are set up separately. As a result, a battery has a different number in the ERP system than in the passport, making traceability unnecessarily difficult in the event of a complaint or recall.

A manufacturer places the QR code for the passport and the chemical symbol from Article 13 separately on the battery, in different sizes and in different locations, without a well-thought-out labelling design. For a larger battery this is still manageable, but on a compact e-bike battery a patchwork of markings quickly develops.

A machine builder incorporates a battery into a larger device and only realises late that the device itself may also fall under a different product passport, with its own data carrier logic. The two passports are then not aligned with each other, creating confusion about which QR code is for what. See for that connection my product requires multiple product passports — how does that work together?.

A company chooses a QR format without taking wear into account: after a few months of use the code is damaged and no longer scannable, and there is no procedure for what should happen then.

What you can record

• The choice for GS1 Digital Link or an alternative data carrier standard, with the reason for that choice
• The product code structure used in the passport, and confirmation that it matches the code in the company's own ERP or inventory system
• A design in which the QR code for the passport and the mandatory labels from Article 13 are combined, including placement and dimensions
• Agreements with the supplier of labels or printed materials on the technical specification of the QR code
• A procedure for what to do in the event of a damaged or unreadable code, including who is responsible for it — see what should I do if the QR code on a battery is no longer readable
• Documentation on the link between the internal system and the hosted passport, so that when changes are made to one system, it is clear what needs to happen in the other — see can I link the battery passport to my ERP or inventory system?