Do You Have to Use GS1 Digital Link for Your DPP?

The short answer

No — the EU's Digital Product Passport standards do not mandate GS1 Digital Link. GS1 Digital Link is the dominant, recommended option, but it is one compliant choice among several. What the standard actually requires is far simpler: a resolvable, globally unique URL. Any syntax that produces one is compliant.

The confusion is understandable. GS1 Digital Link is everywhere in DPP conversations, so many teams assume it is the law. It is not. To see why, you have to separate three things that constantly get merged into one.

The three layers everyone confuses

Most of the "you must use GS1 Digital Link" myth comes from collapsing three distinct layers into a single object. Keep them apart and the picture clears up immediately.

1. 01.The identifier — the what. The GTIN, the serial number, the batch or lot number. This is the piece of data that uniquely names the product, model or item.
2. 02.The syntax — how that identifier is written as a URL. GS1 Digital Link is one such syntax. Example: https://example.com/01/09521207311511/21/1234ABDE.
3. 03.The data carrier — the thing that carries the URL. The QR code, Data Matrix, NFC tag or RFID inlay that physically encodes the URL on or in the product.

The single most common mistake is treating GS1 Digital Link as a data carrier. It is not. GS1 Digital Link is a URI syntax — it is encoded inside a data carrier, not the carrier itself. An analogy: saying the Digital Link is the QR code is like saying writing is the paper. The writing (syntax) is carried by the paper (carrier); they are different layers.

What EN 18219 actually requires

The relevant text is EN 18219 (Unique identifiers), section 5.2.2. It states that the unique product identifier shall either be provided in the form of a URL or be derivable into a URL. That URL must be:

• •Conformant with IETF RFC 3986 (the URI specification)
• •Globally unique, following ISO/IEC 15459-3
• •Issued under a registered Issuing Agency Code, following ISO/IEC 15459-2

Read it carefully: the obligation is a resolvable, globally unique URL backed by a registered issuing agency. The standard never names a single mandatory vendor syntax. It sets an outcome, then lists several ways to reach it.

The compliant options

EN 18219 §5.2.2.2 spells out the syntaxes that satisfy the requirement. You pick one — you do not have to use all of them:

• •(d) GS1 Digital Link URI Syntax — for organisations using the GS1 Application Identifiers; or
• •(e) EN IEC 61406-2 or ISO/IEC 18975 — for organisations using the Data Identifiers of ASC MH10;
• •(f) ISO/IEC 15459-3 — for global uniqueness of the identifier;
• •(g) a registered Issuing Agency Code — per ISO/IEC 15459-2.

In other words, GS1 Digital Link (option d) sits alongside EN IEC 61406-2 and ISO/IEC 18975 (option e) as equally valid ways to express the identifier as a URL. The choice depends on which identifier scheme your systems already use — GS1 Application Identifiers on one side, ASC MH10 Data Identifiers on the other.

EN 18220 (Data carriers) goes further and even provides a decentralised identifier as a worked example, resolved through a resolver:

https://resolver.io/did:web:example.com:model4TR/?service=item-dpp

This is a normative fact, not a recommendation from us: the standard accepts even a did:web identifier resolved via a resolver, because it still produces a valid, globally unique, resolvable URL. The scheme used to express the identifier is open; the outcome — a URL that resolves — is what matters.

How to choose in practice

The decision is not "GS1 Digital Link or bust." It is two independent, practical choices:

1. 01.Pick the identifier syntax that matches your systems. Already run on GS1 Application Identifiers and GTINs? GS1 Digital Link is the natural, recommended fit. Running on ASC MH10 Data Identifiers instead? EN IEC 61406-2 or ISO/IEC 18975 keep you compliant without re-plumbing your identifier scheme.
2. 02.Pick the data carrier that fits your product and its life cycle. A textile item might carry NFC plus a QR code encoding the same URL. A battery needs a durable Data Matrix that survives years of use. A hang tag QR code disappears at first wash. One product can carry several carriers — as long as they all resolve to the same passport.

What stays constant across all of this is the requirement: a resolvable, globally unique URL. There is no lock-in to a single scheme, and no legal obligation to adopt GS1 Digital Link specifically.

In short

GS1 Digital Link is the dominant and recommended way to express a DPP identifier — but it is a recommendation and a syntax, not a legal requirement, and not a data carrier. EN 18219 requires a resolvable, globally unique URL; several syntaxes satisfy that, and EN 18220 shows the door is open even to decentralised identifiers. Choose the identifier syntax that fits your systems, then the data carrier that fits your product.

Arianee operates open DPP infrastructure that supports the identifier syntaxes and data carriers the standards allow — GS1 Digital Link included — without locking you into any single scheme. Discover the platform or start with our DPP vs QR code vs label explainer.

Sources: EN 18219:2026 (final draft, Unique identifiers) · EN 18220:2026 (Data carriers) · GS1 Digital Link Standard: URI Syntax v1.6.0 · EN IEC 61406-1/-2 · ISO/IEC 18975 · ISO/IEC 15459-2 and -3 · IETF RFC 3986.