GPSR Batch Numbers, Serial Numbers and Model Numbers: Product Identification in Practice (with Coding Examples)

What Article 9(5) actually requires

Article 9(5) obliges the manufacturer to ensure that its products bear a type, batch or serial number or other element enabling the identification of the product, easily visible and legible for consumers. Only where the size or nature of the product does not allow this may the information go on the packaging or in an accompanying document.

• 'Or' means one is enough. The text lists alternatives. Legally, a type number alone can satisfy the provision; you are not required to print all three.
• The point is identification. Whatever you choose must let consumers, authorities and you link a physical unit to a specific product. The Commission's business guidelines (C/2025/6233) give a barcode as an example of such an element; the guidelines are interpretation, not the law itself.
• Visible to consumers. A code that only the factory understands, or that is hidden inside the housing, is hard to defend as 'easily visible and legible'.
• The fallback is narrow. The guidelines say that, in principle, only the size of the product, not aesthetics, justifies moving required information to the packaging.

Scope matters. Under Article 2(1), Chapter III Section 1 (Articles 9 to 18) does not apply to products covered by EU harmonisation legislation, such as CE-marked electrical equipment or toys. Their sector laws contain almost identical wording, for example Article 6(5) of the Low Voltage Directive 2014/35/EU and Article 4(5) of the Toy Safety Directive 2009/48/EC, so the practical approach is the same either way. For the full list of label fields, see GPSR label requirements.

Who is responsible and who has to check

In practice this means your EU representative, an EU importer or a marketplace may ask 'where is the batch number?' before listing or during a check. If you sell under your own brand, Article 13(1) makes you the manufacturer, so the duty is yours, not your contract factory's. See economic operator roles for how the roles split.

Type vs batch vs serial number: legal minimum and recall reality

A model number may meet Article 9(5), but it gives you little room when something goes wrong:

• Article 23(3) lets authorities that have identified a dangerous product ask the manufacturer which other products, made with the same procedure, containing the same components or from the same production batch, are affected by the same risk.
• Article 36(2) requires a written recall notice to describe the product with identification numbers such as a batch or serial number and, if applicable, a graphic showing where to find them.
• Recital 42 links product identification directly to 'targeted recalls'.

A hypothetical example: a charger used a faulty component lot in production weeks 44 and 45. With batch codes on every unit and a batch record, you can show the problem is limited to those batches. With only a model number, you cannot show which units are unaffected, and the recall will probably cover the whole model. For the recall process and Safety Gate, see accidents, recalls and Safety Gate.

Designing a simple batch code (example)

The GPSR prescribes no format. Any scheme works if it reliably points to a production record. The following is only an example of a scheme small sellers can run with a spreadsheet:

Format: factory-yearweek-line, e.g. F2-2645-1.

• Start a new batch whenever the factory or line changes, a key material or component comes from a new supplier or lot, the design or firmware is revised, or production restarts after a break, and set a maximum period such as one batch per week or month.
• Fixed length, unambiguous characters: avoid O/0 and I/1 so consumers can read the code out during a recall.
• One code, one record, never reused.
• Prefix the fields: 'Model' or 'Type' before the type, 'LOT' or 'Batch' before the batch code. This is common practice, not prescribed wording.
• Put it in the factory's instructions or purchase contract and check it during pre-shipment inspection.

Where to put it: product, retail packaging, outer carton

• On the product first: rating plate, base or back, anywhere visible without tools. Moulded date inserts, laser marking, pad printing and durable labels all work.
• Repeat it on the retail packaging: it helps retail staff, marketplace reviewers and returns handling. But consumers throw packaging away, so during a recall they often only have the product. Do not rely on packaging alone unless size really prevents marking.
• Small items: earrings, small accessories or memory cards may carry the identifier on the packaging, a hang tag or the leaflet under Article 9(5); be ready to explain why the product itself is too small.
• Cartons and shipping labels do not count: they never reach the consumer.
• Durability: Articles 11(5) and 12(2) require importers and distributors to make sure storage and transport do not jeopardise compliance with Article 9(5). Stickers that fall off and inkjet codes that rub off cause trouble during repackaging or when returns are restocked.
• QR codes only in addition: a QR code can link to batch information, but Article 21 allows digital information only on top of the physical marking. See QR codes and digital labels.

How EAN/GTIN, ASIN, SKU and FNSKU relate to a batch number

If you want one barcode to carry both, GS1 standards have dedicated data fields for batch/lot and serial number (Application Identifiers 10 and 21) that can be encoded in GS1-128 or two-dimensional symbols. That is your choice; the GPSR does not prescribe any barcode format.

Online, Article 19(c) requires the offer to show a picture, the type and any other product identifier. Neither the regulation nor the guidelines say that each batch number must be shown in the listing; what matters is that the model and pictures match the physical product. See online selling requirements.

Batch records: what to keep and for how long

A batch code is only useful with a record behind it. Under Article 15(3), economic operators must, on request, identify any economic operator that supplied them with the product or with a part, component or embedded software, and any economic operator they supplied. Article 15(5) requires this traceability information to be available for six years after being supplied or supplying. Risk descriptions, complaints, known accidents and corrective measures (Article 15(2)) must be available for 10 years (Article 15(4)), and technical documentation is kept for 10 years after placing on the market (Article 9(3)). This concerns business-to-business links, not individual consumers.

Article 15 is also in Chapter III Section 1, so for CE-marked products the sector law applies instead; Article 11 of the Low Voltage Directive and Article 9 of the Toy Safety Directive both require supplier and customer information for 10 years. Use the longest period that applies to you.

A simple batch record (example, fictional values):

Link it to the register of complaints, recalls and corrective measures required by Article 9(12): log the batch code with every complaint and you will spot a problem batch early. See technical documentation.

Article 18: a dedicated traceability system for high-risk products

Article 18 allows the Commission, for products or categories likely to present a serious risk based on accident data, Safety Gate statistics and other evidence, and after consulting stakeholders, to set up a traceability system that operators placing or making those products available must follow. It would involve collecting and storing data identifying the product, its components or the operators in its supply chain, and rules for displaying and accessing that data, including a data carrier on the product, packaging or accompanying documents (Article 18(2)). The products, data and access rights are to be set by delegated acts (Article 18(3)), taking account of cost-effectiveness, the impact on SMEs and an adequate preparation period (Article 18(5)).

As of the date we checked this page (7 November 2026), we have not found any delegated act adopted under Article 18, so there is currently no category-specific GPSR traceability system. If one arrives for your category, a working batch scheme and records are the best starting point. To see what else you may be missing, take the three-step compliance check.