Product identification under GPSR: type, batch, serial number and GTIN
If a product turns out to be dangerous, authorities and consumers need to know exactly which items are affected. That is why the GPSR requires identifiers on the product and identifying information, including a picture, on every online listing.
In short
- Manufacturers must put a type, batch or serial number or another element on the product that consumers can see and read (Article 9(5)).
- Online offers must show information to identify the product, including a picture, its type and any other product identifier (Article 19(c)).
- A GTIN or SKU is useful, but it usually identifies the model, not the batch. For recalls, a batch or lot reference is what counts.
- Use real photos of the product being sold, per variant, not stock images of another model.
Two separate requirements
The GPSR asks for identification in two places:
| Where | Rule | What is required |
|---|---|---|
| On the product | Article 9(5) | A type, batch or serial number or other element allowing identification, easily visible and legible for consumers. If the size or nature of the product does not allow it, on the packaging or in an accompanying document. |
| On the online listing | Article 19(c) | Information allowing the identification of the product, including a picture of it, its type and any other product identifier. |
The first is the manufacturer's job. The second is the job of whoever runs the online offer, which for a Shopify store is you. As a distributor you also have to check that the manufacturer's identification is on the product before you sell it (Article 12).
Which identifiers to use
Type or model
The model name or number (for example “Trail Lamp TL-200”) identifies the design. It is the minimum, and it should match what is printed on the product.
Batch, lot or serial number
A batch or lot number groups items made together. A serial number identifies one single item. These are what make a targeted recall possible: authorities can say “batches 2405 to 2411 are affected” instead of recalling every unit ever sold. If your products carry a batch number, record which batch each order shipped from if you can.
GTIN, EAN or UPC
The GTIN (the number behind the barcode) identifies the trade item, usually per variant. It is an excellent “other product identifier” for the listing and it is required for some marketplaces. It does not identify the batch on its own. GS1 Digital Link QR codes can carry both the GTIN and the batch, which is why they are becoming common for product passports.
SKU
Your internal SKU identifies the item in your store. It helps, but on its own it means little to an authority or consumer unless it is also printed on the product.
The picture requirement
Article 19(c) explicitly mentions a picture. In practice:
- every product needs at least one photo of the actual product;
- variants that look different (colour, size, version) should each show their own photo;
- bundles should show what is in the bundle;
- stock photos of a similar but different model do not identify the product being sold.
Traceability systems for high-risk products
Article 18 allows the Commission to set up a traceability system for products or categories likely to present a serious risk. Economic operators would then have to record and share specific data through it. No such system needs to be followed by default, but keeping batch data now makes any future requirement much easier.
Setting this up in Shopify
- Use the barcode field for the GTIN on each variant.
- Keep the model or type in a dedicated field rather than only in the title.
- Record whether the product is tracked by batch or serial number, and where it is printed.
- Show the type and identifiers in your product page GPSR block next to the manufacturer details.
Sources
- Regulation (EU) 2023/988 (GPSR), Articles 9(5), 18 and 19(c), EUR-Lex
- GS1: GTIN, the Global Trade Item Number
This guide explains EU rules in general terms and is not legal advice. National rules and guidance can add requirements. Check the sources and, for your specific products, ask a lawyer or the competent authority. Last checked 31 October 2026.