Does the GPSR Require a GTIN, and What Counts as Identifying a Product?
No. Article 9 asks for a type, batch or serial number or another element allowing identification. It names no scheme. A retailer asking is not the law.
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No. The GPSR asks for identification, not for a particular identifier. Article 9 requires a product to bear a type, batch or serial number or another element allowing the product to be identified, and that is a functional requirement a code you already use can satisfy.
- Nothing in Regulation (EU) 2023/988 names GTIN, EAN, UPC or any other scheme. A GTIN can satisfy the requirement and so can an internal type number.
- Article 9 puts identification on manufacturers, Article 11 on importers and Article 19 on whoever makes a distance offer.
- Under Article 19 the identification a distance buyer sees includes a picture of the product.
- The GPSR does not require a barcode, a GS1 scheme, a digital identifier or a URL.
- A GTIN is frequently required by a retailer, marketplace or trading partner. That is a commercial requirement, not the GPSR.
Nothing in Regulation (EU) 2023/988 names GTIN, EAN, UPC or any other scheme. A GTIN can satisfy the requirement. So can an internal type number, if it identifies the product and is on it.
This is the same shape as the answer on the Digital Product Passport side, and for the same reason: a law that named one commercial scheme would be a law that made one standards body's membership compulsory.
What the GPSR actually asks for
Three requirements, on three actors, all in Regulation (EU) 2023/988:
| Article | Who | What |
|---|---|---|
| 9 | Manufacturers | The product bears a type, batch or serial number or other element allowing identification, easily visible and legible for consumers. And the manufacturer's name, registered trade name or registered trade mark and contact address, on the product or, where that is not possible, on the packaging or an accompanying document. |
| 11 | Importers | The same identification is present, and the importer's own name, trade name and contact address, without obscuring the manufacturer's marking. |
| 19 | Whoever makes a distance offer | The offer indicates information identifying the product, including a picture of it. |
Article 19 is the one that surprises people. The identification that has to reach a consumer buying at a distance includes a picture. A part number on its own is not the whole of what that article asks the offer to show.
Why "does it require a GTIN" keeps being asked
Because two different requirements get collapsed into one.
A GTIN is frequently required, but by a retailer, a marketplace or a trading partner, as a condition of doing business. That is a commercial requirement and it is often non-negotiable. It is not the GPSR.
Where the two point in different directions, a commercial requirement can be renegotiated, clarified or satisfied another way, and a legal one cannot. Treating a trading-partner rule as law means never asking the question that would have resolved it.
The same boundary, for identifiers generally, is set out on barcodes and product identifiers.
How it maps onto identifiers you already hold
Most businesses are already carrying something that can do this work:
- A type or model number identifies the product as a model. Where the safety question is
about a model, this is usually the element Article 9 is describing.
- A batch or lot number identifies a production run. It makes a targeted recall
possible rather than a total one, so it tends to be the one that matters when something goes wrong.
- A serial number identifies the individual item. Necessary for some products, expensive
for most.
- A GTIN identifies the trade item. It is a commercial identity that can also serve as
the identifying element.
Which of these you need is a granularity decision rather than a compliance lookup. See a passport needs three identifiers: the same thinking applies here even though the regime is different.
If the number you intend to use is a GTIN, its structure is worth confirming before it goes into a listing or a label. You can check the length and the check digit, which is a structural test and not evidence that the number was allocated to you.
What the GPSR does not ask for
- It does not require a barcode. Identification is about the element, not the symbology.
- It does not require a GS1 scheme, or any scheme.
- It does not require a digital identifier or a URL. A printed number is an element allowing
identification.
- It does not make the identifier a safety measure. An identifiable dangerous product is
still a dangerous product; identification is what makes tracing and recall possible.
What this page does not own
It does not list the four groups of information an online offer must indicate. That is what an EU online offer must show.
It does not cover what a Digital Product Passport requires of an identifier. Different regime, different answer. It is owned by barcodes and product identifiers.
What would change this answer
Recheck if:
- Article 9, 11 or 19 of Regulation (EU) 2023/988 is amended;
- the Commission issues guidance on what "other element allowing the product to be
identified" covers;
- a sectoral instrument imposes a specific identification scheme for a product group, which
would sit on top of this rather than replace it.
Last verified 12 September 2026.
Keep exploring
The questions this page usually raises next.
- CompareNext questionWhat Product Information Must an EU Online Listing Show Under the GPSR?The manufacturer, responsible person, product identifiers and safety information an online offer to EU consumers must indicate.
- Another angleNext questionBarcodes and Product Identifiers: What You NeedWhat a barcode has to do before a passport can hang off it, how to start if nothing has been allocated to you, and what an…
- Another angleNext questionProduct, Operator and Facility Identifiers for a DPPThe passport identifier standard describes three identifiers, not one: product, economic operator and facility.
Sources and legal basis
Does this reach your products?
Give ActivateDigital one product and it works out which obligations apply from the product's own character, and says which it cannot decide.