The second provisional GS1 release for the Digital Product Passport makes an important distinction: Near Field Communication (NFC) may complement access to product data, but it is not intended to replace the two-dimensional data carrier. For manufacturers, this is not a signal to add a chip to every product immediately. It is an architectural cue: one product may provide several physical access paths, but every path must lead to the same dependable product identity.
The occasion is concrete. GS1 lists the June 2026 publication as an updated provisional DPP standard following work on Individual Trade Item Pieces (ITIP) and NFC. At the same time, the GS1 document for the second provisional release states unequivocally that it is not yet a ratified GS1 standard and that all aspects may change before ratification. It is therefore useful for technical preparation, but it should not be the sole basis for binding procurement requirements.
What EU law requires — and what remains open
The Ecodesign for Sustainable Products Regulation (EU) 2024/1781 establishes the legal framework. Under Article 9, product-specific delegated acts will determine, among other things,
- whether one or more data carriers must be used,
- where those carriers must be placed,
- whether the passport is defined at model, batch or item level, and
- how long the passport must remain available.
Article 10 requires the passport to be connected to a persistent unique product identifier through a data carrier. Depending on the relevant act, that carrier must be physically present on the product, its packaging or accompanying documentation. It is therefore not merely a marketing link. It is the physical bridge to a defined product identity.
The infrastructure that became operational on 20 July 2026 does not change those roles. The European Commission’s DPP overview describes the process: product information is gathered, the passport is registered, the complete data remains with the economic operator or a service provider, and users access information according to their rights. Product-specific legislation will later determine details such as carrier type, placement and granularity.
The provisional GS1 release consequently describes one possible standardised implementation. It neither makes NFC universally mandatory nor pre-empts EU decisions for individual product groups.
NFC is an additional channel, not a replacement for the 2D code
The provisional GS1 release identifies two visual carriers for DPP access:
- QR Code with GS1 Digital Link URI syntax,
- Data Matrix with GS1 Digital Link URI syntax.
NFC may be used in addition to the 2D barcode. EPC/RFID is also treated as an additional carrier during a transition period. The NFC rationale is particularly clear: it should not be proposed as a potential replacement for 2D because it is inappropriate for use in the open supply chain.
This distinction matters in practice. A person can see a 2D code and capture it with a smartphone’s native camera. It can be printed, inspected visually and recognised across multiple process stages. NFC offers a convenient tap interaction, but it is invisible and depends on compatible reading equipment as well as a clear indication of where the interaction should occur.
An NFC tag can therefore be useful when the product already contains electronics, when the carrier needs protection from dirt or abrasion, or when contactless access improves a service process. It does not automatically satisfy the need for an open, visible and broadly usable access path. Under today’s provisional GS1 model, an NFC-only architecture would not be a robust general DPP strategy.
Two carriers must convey the same identity
The most important technical point is not the radio chip but identity consistency. If data elements appear in more than one carrier, they must have the same value. This can include the GTIN and, for item-level identification, the serial number.
A common failure mode would be to generate the printed code from a packaging system while programming the NFC tag from a separate device database. Even small differences in serial numbers, leading zeros or version qualifiers may create two apparently valid but contradictory identities. The passport may remain technically reachable while no longer being unambiguously linked to the physical product.
A safer sequence is:
- Establish the authoritative product identity first.
- Generate a canonical GS1 Digital Link URI from that identity.
- Derive every intended carrier from the same identity.
- Automatically compare QR Code, Data Matrix and NFC against the master data.
This principle also supports the goal of one dependable entry point per product. Our article on PPWR, QR Codes and DPPs explains why a single 2D code can support several purposes. The provisional GS1 release adds an important limitation: if an existing GS1 application standard does not yet permit the new 2D carrier as an alternative, an additional barcode may be required temporarily. “One code for everything” is therefore a target architecture, not a universal approval.
What release two means for ITIP and granularity
Besides NFC, the update addresses ITIP — individual pieces contained in a trade item made up of several pieces. The provisional release identifies GS1 Application Identifier 8006 for this purpose, but limits its use to defined situations. For most companies, the individual number matters less than the question behind it: which physical entity is supposed to receive its own passport?
The answer should not be inferred from the preferred carrier. It follows from the relevant legislation and business process:
- A model-level passport describes shared properties of a product variant.
- A batch-level passport connects information to a production lot.
- An item-level passport enables instance-specific service, repair or lifecycle information.
- For multi-part products, teams must decide whether individual pieces are products in their own right or components referenced by a parent passport.
Only then is it possible to determine whether the GTIN alone is sufficient or must be qualified by a batch, version or serial number. Companies that order QR labels or NFC tags first and define granularity later risk reprinting, reprogramming and inventories with identities that cannot be reconciled.
A robust introduction plan
1. Document the identity contract
For each product group, record which entity is identified, who allocates the key and which system is authoritative. Include the rules for versions, batches and serial numbers. The identifier must not depend on one output channel.
2. Use a carrier matrix, not a blanket decision
Assess QR Code, Data Matrix and NFC separately for available space, material, lifetime, reading distance, audience and existing processes. Data Matrix may be more suitable for small or cylindrical parts; QR Code is a natural choice for native smartphone-camera access; NFC can complement service workflows. The final selection remains subject to product-specific legislation.
3. Maintain one canonical resolution layer
Every carrier should lead to a stable resolution path under controlled governance. Content may change during the product lifecycle without reassigning the physical identity. Our article on GS1 Sunrise 2027 explains how a 2D code can connect commerce and information processes.
4. Test parity automatically
Do not test merely whether both carriers “open something.” A release test should confirm at least that:
- the extracted product key and qualifiers are identical,
- the canonical destination is correct,
- mobile devices reach the information released for public access,
- protected roles do not accidentally receive public data,
- damaged or obsolete carriers lead to a defined error state, and
- resolution remains stable after content changes.
5. Treat provisional rules as changeable
Mark technical decisions that rely directly on the second provisional GS1 release. They can then be reviewed when the standard is ratified, when GS1 issues further changes, or when product-specific EU requirements arrive. Hardware procurement should preserve enough flexibility that a later adjustment to the carrier choice does not block the entire product design.
Conclusion
The new provisional GS1 release shifts the question from “QR or NFC?” to “one identity with several controlled access paths.” In the proposed model, the 2D code remains the visible and open foundation. NFC can improve usability if it is used as an addition, programmed from the same identity source and verified against the printed carrier.
Now is the right time for companies to prepare identity, resolution and testing processes. The release does not establish a general NFC mandate, and it is not yet a ratified standard. Carrier choice and granularity only become binding through the combination of applicable EU legislation and final standards.
