GS1 Digital Link and PPWR: What Businesses Need to Know

What is the GS1 Digital Link?

The GS1 Digital Link is a standardised URL format that connects a GTIN (Global Trade Item Number, i.e. the barcode product code) with a web link. Rather than a simple QR code pointing to an arbitrary URL, the GS1 Digital Link contains structured, machine-readable information in accordance with ISO/IEC 18975 and the GS1 standard.

A typical GS1 Digital Link looks like this: `https://id.gs1.org/01/04012345678901`

Encoded within it is the product's GTIN (`01` is the GS1 Application Identifier for GTINs, followed by the 14-digit number). Via this link, point-of-sale systems, scanners, recycling apps and consumers can directly access structured product data.

Why is this relevant to the PPWR?

The PPWR stipulates that packaging must provide certain digital product information from 12 August 2026 onwards – including recycling instructions, material composition and manufacturer information. This information must be machine-readable and retrievable via a standardised data carrier.

The GS1 Digital Link is the format recommended by GS1 and the European Commission for meeting these requirements. It combines the existing GTIN infrastructure with the ability to link to current, dynamically updatable data content.

Sunrise 2027: What Does It Mean?

"Sunrise 2027" refers to the point from which point-of-sale systems in retail are required to be capable of reading QR codes based on the GS1 Digital Link at the checkout – that is, using them as a barcode replacement. This date was originally set by GS1 globally for January 2027.

Until Sunrise 2027, QR codes on packaging must be applied in addition to the traditional barcode (EAN-13 etc.). From that date, the GS1 Digital Link QR code may replace the conventional barcode at the point of sale. For your planning, this means: if you wish to be PPWR-compliant from August 2026 while also ensuring checkout compatibility, you will need both codes on the packaging during the transition period.

GTIN Requirement: Does Every Product Need a GTIN?

A GTIN is technically mandatory for the GS1 Digital Link – it is the core of the URL structure. Companies that have not previously assigned GTINs (for example, manufacturers selling only regionally or directly) must licence them through GS1 Germany.

The annual fee at GS1 Germany starts at approximately €150 to €300 depending on company size and number of products. One-off costs for the GLN (Global Location Number) and basic registration are additional. Small businesses should plan this step well in advance, as registration can take several weeks.

Difference from a Dynamic QR Code

An ordinary dynamic QR code (such as those generated by QR code generators) contains an arbitrary URL and is not structured. It cannot be interpreted by point-of-sale systems as a product identifier and does not conform to the GS1 standard.

The GS1 Digital Link, by contrast, follows a defined URI scheme that encodes product identifiers, batch numbers, expiry dates and further attributes in a standardised manner. Only this format meets the technical requirements for Sunrise 2027 and is PPWR-compatible.

When is the GS1 Digital Link Not Required?

Not all packaging is subject to the PPWR digital labelling obligation to the same extent. In particular:

• Very small packaging (below certain size thresholds) may benefit from exemptions.
• Primary packaging in the B2B sector without consumer contact is partially subject to different rules.
• Unpackaged goods are not subject to the labelling obligation.

For a binding assessment of whether and to what extent your products are affected, we recommend contacting your competent Chamber of Commerce or a consultant specialising in packaging law.