Guide for manufacturers and exporters
Traceability Requirements in 2026: GS1 Standards and EU Rules by Industry
Updated 30 October 2026. Written by the Ajinkya Technologies engineering team, reviewed by Amey Kadle. Dates checked against the legal texts linked below; we update this page when a delegated act or date changes. This is a technical guide, not legal advice.
The short answer
Traceability requirements make manufacturers identify their products, record where they came from and where they went, and share that data on request. In the EU the strictest rules today cover medicines, medical devices, food and tobacco. Product passports follow for batteries in 2027, detergents in 2029 and toys in 2030, with steel, aluminium and textiles next in line. Most of these rules can be met with one design built on GS1 identifiers, 2D codes or RFID, and shared event data.
Jump to the compliance checklistKey dates, 2024 to 2030
13 Dec 2024
General Product Safety Regulation applies: type, batch or serial number on consumer products, supplier and customer records kept for 6 years.
31 Jan 2025
India: DGFT withdraws the pharma export track and trace rule (Public Notice 44/2024-25).
1 Jan 2026
CBAM definitive period starts for iron, steel, aluminium and other covered imports.
8 Jan 2026
Construction Products Regulation applies: product type code plus batch or serial number.
28 May 2026
First four EUDAMED modules become mandatory for medical devices.
19 Jul 2026
Ban on destroying unsold apparel, clothing accessories and footwear applies to large companies.
20 Jul 2026
The EU Digital Product Passport registry goes live.
12 Aug 2026
Packaging and Packaging Waste Regulation applies.
18 Sep 2026
Leather is removed from the scope of the EU Deforestation Regulation.
30 Dec 2026
EU Deforestation Regulation applies (micro and small operators from 30 Jun 2027).
18 Feb 2027
Battery passport required for EV, light means of transport and industrial batteries over 2 kWh.
26 May 2027
UDI carrier required for class A in vitro diagnostic devices.
30 Sep 2027
First annual CBAM declaration due, covering 2026 imports.
End of 2027
GS1 Ambition 2027: retail checkouts able to read GS1 DataMatrix and QR codes with GS1 Digital Link.
17 Apr 2028
Extended producer responsibility schemes for textiles and footwear in every member state.
23 Sep 2029
Digital Product Passport for detergents.
1 Aug 2030
Digital Product Passport for toys; customs release only after a registry check.
EU traceability rules by industry
What each rule asks you to trace, which data carrier it expects and when it applies. Follow the rule name to the legal text.
| Industry | Rule | What must be traceable | Data carrier | Dates |
|---|---|---|---|---|
| Prescription medicines | Falsified Medicines Directive 2011/62/EU and Delegated Regulation (EU) 2016/161 | A unique identifier on every pack (product code, serial number, batch, expiry) plus an anti tampering device; verified against the EU repositories system | Data Matrix (GS1 DataMatrix in practice) | Applies since 9 Feb 2019 |
| Medical devices and IVDs | MDR (EU) 2017/745 and IVDR (EU) 2017/746 | UDI device identifier and production identifier on labels and packaging, registration in EUDAMED; issuing entities are GS1, HIBCC, ICCBBA and IFA | Linear barcode, 2D code or RFID, plus human readable text | EUDAMED modules mandatory 28 May 2026; IVDR class A carrier 26 May 2027 |
| Food and feed | General Food Law (EC) 178/2002, Article 18; Regulation (EU) 931/2011 for food of animal origin | One step back and one step forward: suppliers, customers, products; for food of animal origin also lot, quantity and dispatch date, updated daily | None prescribed | Since 1 Jan 2005; 931/2011 since 1 Jul 2012 |
| Tobacco products | Tobacco Products Directive 2014/40/EU, Article 15, and Regulation (EU) 2018/574 | A unit level unique identifier from a state appointed issuer; events reported to repositories from manufacturer to the first retail outlet | Data Matrix, QR or DotCode (Code 128 allowed on aggregates) | Cigarettes since 20 May 2019, other products since 20 May 2024; 3 hour reporting from 20 May 2028 |
| Consumer products in general | General Product Safety Regulation (EU) 2023/988 | Type, batch or serial number on the product; manufacturer postal and email address; supplier and customer records kept for 6 years | None prescribed yet; the Commission may require one for serious risk products | Applies since 13 Dec 2024 |
| Toys | Toy Safety Regulation (EU) 2025/2509 | A model level Digital Product Passport replaces the declaration of conformity; identifiers go to the EU registry | Data carrier on the toy or its label | Applies 1 Aug 2030; customs release only after a registry check |
| Batteries | Batteries Regulation (EU) 2023/1542 | A battery passport for EV, light means of transport and industrial batteries over 2 kWh | QR code | From 18 Feb 2027 |
| Detergents | Detergents Regulation (EU) 2026/405 | A model level Digital Product Passport, checked at customs | Data carrier linked to the passport | Applies 23 Sep 2029 |
| Construction products | Construction Products Regulation (EU) 2024/3110 | Product type code plus batch or serial number; a passport through a construction DPP system | Data carrier per the delegated act | Applies since 8 Jan 2026; the passport becomes mandatory 18 months after its delegated act, which is not yet adopted |
| Packaging | Packaging and Packaging Waste Regulation (EU) 2025/40 | Type, batch or serial number; harmonised sorting labels; reusable packaging tracked by trip; one shared carrier when the product also needs one | Optional QR or other open data carrier; required for reusable packaging | Applies 12 Aug 2026; labels from 12 Aug 2028 at the earliest |
| Iron, steel and aluminium | CBAM Regulation (EU) 2023/956; ESPR delegated acts (planned) | Embedded emissions per installation and product for CBAM declarations; a product passport once the steel and aluminium delegated acts are adopted | Per delegated act (not yet published) | CBAM definitive since 1 Jan 2026, first declaration 30 Sep 2027; no steel passport date confirmed |
| Textiles, apparel, footwear, leather goods | ESPR (EU) 2024/1781 and Directive (EU) 2025/1892 | Disclosure of unsold products discarded and a ban on destroying them; a textile passport once its delegated act is adopted; producer registration for EPR in each member state | QR code expected for the textile passport | Destruction ban since 19 Jul 2026 (large firms); EPR schemes by 17 Apr 2028; textile passport act planned for 2027 |
| Wood, cattle, cocoa, coffee, oil palm, rubber, soya | EU Deforestation Regulation (EU) 2023/1115, as amended | A due diligence statement with the geolocation of every plot, production dates, quantities, suppliers and customers | None; statement reference numbers pass downstream | Applies 30 Dec 2026; micro and small operators 30 Jun 2027; leather removed 18 Sep 2026 |
The Digital Product Passport: what is decided and what is not
The Ecodesign for Sustainable Products Regulation (ESPR) has been in force since 18 July 2024. It lets the Commission require a passport for a product group through a delegated act; the passport is reached through a data carrier on the product and linked to a persistent unique identifier at model, batch or item level, as each act decides. ESPR Annex III names the GTIN as an acceptable identifier, and the EU registry for passport identifiers went live on 20 July 2026.
The Commission’s working plan of 16 April 2025 puts iron and steel, aluminium, textiles and apparel, furniture, tyres and mattresses first, with repairability and recyclability rules for electronics. A delegated act applies no earlier than 18 months after it enters into force. By 30 October 2026 no steel or textile act had been published, so no steel or textile passport date is confirmed. Batteries, detergents and toys have their own dates in their own regulations, listed above.
GS1’s provisional passport application standard, not yet ratified, uses a QR code or GS1 DataMatrix carrying a GS1 Digital Link, with RFID allowed only in addition to one of those. Designing your codes that way now means the same carrier can serve retail checkout, consumers and the passport.
GS1 standards you will build on
- GTIN
- Identifies a trade item: anything priced, ordered or invoiced. Named in ESPR Annex III as an acceptable product identifier.
- SGTIN
- A GTIN plus a serial number, giving each individual item its own identity; what item level traceability and authenticity checks need.
- SSCC
- Identifies a logistic unit such as a pallet or carton through the whole supply chain.
- GLN
- Identifies parties and physical locations: plants, warehouses, docks.
- GRAI and GIAI
- Identify returnable assets (crates, kegs, racks) and individual fixed assets.
- GS1-128
- A linear barcode for logistics labels that carries GS1 data such as SSCC, batch and dates.
- GS1 DataMatrix
- A compact 2D code used on medicines, devices and small parts; carries GTIN, serial, batch and expiry.
- GS1 Digital Link
- Expresses GS1 identifiers as a web address inside a QR code or DataMatrix, so one code serves checkout, consumers, inspectors and a passport.
- EPC UHF Gen2 RFID
- The air interface for RAIN RFID tags read at a distance and in bulk; tags carry an EPC such as an SGTIN or SSCC.
- EPCIS 2.0 and CBV
- The standard for sharing traceability events (what, when, where, why and how) and the vocabulary that keeps them consistent.
Plain definitions: GS1 standards, EPCIS, GS1 Digital Link, RFID, Digital Product Passport.
Luxury, fashion and leather
Premium brands face three pressures at once. Counterfeits: EU customs detained about 196 million suspected counterfeit items worth about €6.3 billion in 2025, the highest value recorded. Regulation: since 19 July 2026 large companies may not destroy unsold apparel, clothing accessories and footwear and must disclose what they discard, a textile passport act is planned for 2027, and every member state must run producer responsibility schemes for textiles and footwear by 17 April 2028, including for sellers outside the EU. Customers: buyers of high value goods increasingly expect to verify origin and authenticity themselves.
The industry has already moved. The Aura consortium, founded in 2021 by Prada Group, LVMH and Cartier (Richemont), gives products a verifiable history and now markets a passport for ESPR. The building blocks are the same as for regulated traceability: a serialised identity per item (often a GS1 Digital Link QR code, or an NFC or RFID tag inside the product), events captured from production to boutique, and a resolver that checks every scan against those events.
Leather was removed from the EU Deforestation Regulation from 18 September 2026, but cattle remain in scope, and brand and customer due diligence on hides continues regardless.
Notes for Indian exporters
- Pharma: DGFT withdrew its export track and trace rule on 31 January 2025 (Public Notice 44/2024-25). EU bound prescription medicines still need the FMD unique identifier and anti tampering device.
- Steel and aluminium: CBAM’s definitive period started on 1 January 2026, and EU importers file the first annual declaration by 30 September 2027. Expect buyers to ask for installation level emissions data tied to heat numbers and mill test certificates.
- Identifiers: GS1 India issues company prefixes and runs DataKart, the national product data repository. Most EU retail, device and passport uses start from those identifiers.
- Leather goods and textiles: plan for the textile passport and producer registration in each EU member state, and keep hide and material origin records even though leather left the deforestation rules.
Related: what is CBAM, heat numbers, mill test certificates, steel product traceability.
How to build one traceability system for several rules
- 1
Map obligations per product and market
List every rule that applies to each product family and destination, with the identifier level (model, batch or item), the data each rule needs and the date it starts.
- 2
Fix your identifiers
Obtain a GS1 company prefix (GS1 India for Indian companies), assign GTINs to products and SSCCs to logistic units, and decide where serial numbers are needed.
- 3
Choose carriers that serve several rules
Prefer a GS1 DataMatrix or a QR code with GS1 Digital Link, which can serve checkout, consumers and a passport; add RFID where you need fast or bulk reads.
- 4
Capture events where they happen
Record commissioning, packing and aggregation, shipping, receiving and transformation as events with identifiers, time, place and reason, ideally in an EPCIS compatible model.
- 5
Connect the systems
Link line printers, vision verification, RFID readers, MES, WMS and ERP so identifiers and events are created once and reused, not retyped.
- 6
Publish and protect product data
Run a resolver for Digital Link codes, keep passport data current, enrol identifiers in the EU registry when a delegated act requires it, and control who can see what.
- 7
Prove it with a mock recall
Trace a real lot backward and forward and time it; run an authenticity check on a serialised item. Fix the gaps before an auditor or customer finds them.
How we build it
We design and run traceability on the shop floor and in the warehouse, not just in a database. That means GS1 identifier design, printing and verifying GS1 barcodes and DataMatrix at line speed, serialisation and aggregation from unit to case to pallet, RFID tag selection and portals, event capture integrated with MES, WMS and SAP, and GS1 Digital Link resolvers with authenticity checks.
- Our steel plant material tracking links heat numbers through rolling, cutting and dispatch and handles more than 720,000 material movements a day (company reported).
- Our RFID paint warehouse system processes 16,800 barrels an hour (company reported).
- Some of our traceability and authentication systems already run for premium luxury brands.
Free checklist: EU traceability requirements by product
An Excel workbook with every rule on this page: scope, identifier level, data carrier, data fields, dates and the legal link, plus a self assessment sheet to score your readiness per product family and a mock recall log.
Questions
Is the EU Digital Product Passport mandatory now?
Not for most products yet. The ESPR framework has been in force since 18 July 2024 and the registry went live on 20 July 2026, but each product group needs its own delegated act, which applies at least 18 months after it enters into force. Batteries (from 18 February 2027), detergents (23 September 2029) and toys (1 August 2030) have dates set in their own regulations.
Which products will need a Digital Product Passport first under ESPR?
The Commission’s working plan of 16 April 2025 prioritises iron and steel, aluminium, textiles and apparel, furniture, tyres and mattresses, plus repairability and recyclability rules for electronics. No steel or textile passport date had been confirmed by 30 October 2026.
Do I have to use GS1 standards to comply?
Not always, but they are the common route. ESPR Annex III names the GTIN as an acceptable product identifier, GS1 is one of four EU issuing entities for medical device UDI, and medicine packs carry their identifier in a Data Matrix. GS1 has a provisional, not yet ratified, application standard for passports using QR or DataMatrix codes with GS1 Digital Link.
Do Indian exporters need GS1 barcodes for the EU?
Many EU buyers and several EU rules expect GS1 identifiers, and Indian companies obtain them through GS1 India. Requirements depend on the product: medicines for the EU still need FMD serialisation, devices need UDI, and passports will follow each delegated act.
What happened to DGFT’s pharma export track and trace rule?
DGFT Public Notice 44/2024-25 of 31 January 2025 withdrew the rule with immediate effect. It does not remove EU requirements: prescription medicines exported to the EU still need the FMD unique identifier and anti tampering device.
Is leather covered by the EU Deforestation Regulation?
No longer. Leather was removed from the scope from 18 September 2026. Cattle and other covered commodities remain, and the regulation applies from 30 December 2026.
What is the difference between EPCIS and a Digital Product Passport?
EPCIS records and shares events in a product’s life, such as packing, shipping and receiving. A passport publishes product information required by a regulation, such as materials or repairability, linked to the product by a data carrier. Event data often feeds the passport.
How do luxury brands use traceability against counterfeits?
They give each item a serialised identity, often a GS1 Digital Link QR code or an NFC or RFID tag, and check every scan against production and shipment records. EU customs detained about 196 million suspected counterfeit items worth about €6.3 billion in 2025, which is why item level authentication is spreading.
Sources
- Regulation (EU) 2024/1781, Ecodesign for Sustainable Products (EUR-Lex)
- European Commission: Digital Product Passport
- European Commission: the Digital Product Passport registry is live (20 July 2026)
- European Commission: ESPR working plan (16 April 2025)
- European Commission: Regulation on deforestation free products
- Delegated Regulation (EU) 2026/2102 amending the EUDR (EUR-Lex)
- European Commission: four EUDAMED modules mandatory from 28 May 2026
- Delegated Regulation (EU) 2016/161, safety features for medicines (EUR-Lex)
- Regulation (EC) 178/2002, General Food Law (EUR-Lex)
- Regulation (EU) 2023/988, General Product Safety (EUR-Lex)
- Regulation (EU) 2025/2509, Toy Safety (EUR-Lex)
- Regulation (EU) 2023/1542, Batteries (EUR-Lex)
- Regulation (EU) 2025/40, Packaging and Packaging Waste (EUR-Lex)
- Implementing Regulation (EU) 2018/574, tobacco traceability (EUR-Lex)
- Directive (EU) 2025/1892, textile extended producer responsibility (EUR-Lex)
- European Commission: Carbon Border Adjustment Mechanism
- European Commission DG TAXUD: IPR enforcement facts and figures
- GS1: identification keys
- GS1: EPCIS and Core Business Vocabulary
- GS1 Global Traceability Standard
- GS1 Digital Link URI syntax
- GS1 US: Sunrise 2027
- GS1 in Europe: provisional DPP application standard (not ratified)
- DGFT Public Notice 44/2024-25 (31 January 2025)
- GS1 India: DataKart
- Aura Consortium