A trading name of A Star Supply · ContactA trading name of A Star Supply · ContactEvery product sold to EU consumers needs something that identifies it. The regulation leaves the format open, which is why sellers are unsure what counts. Here is what the text says, and why the number matters when something goes wrong.
Manufacturers must ensure their products bear a type, batch or serial number or other element enabling the identification of the product, which is easily visible and legible for consumers.
The four options are alternatives. The regulation does not prescribe a format, length or numbering scheme. The Commission's 2025 guidelines give a barcode as an example of an "other element enabling its identification".
The test in the text is identification: the element has to let someone identify the product, and consumers have to be able to see and read it.
Where the size or nature of the product does not allow it, Article 9(5) says the information must be provided on the packaging or in a document accompanying the product.
The Commission's guidelines say the choice of where to display it is yours within that framework, that you should be able to justify it in a dispute, and that in principle only the size of the product, and not for example aesthetic reasons, could justify moving required information off the product.
Recital 42 explains the aim: product identification helps take effective and proportionate corrective measures, such as targeted recalls.
Importers must ensure, before placing a product on the market, that the manufacturer has complied with Article 9(5) (Article 11(1)). Distributors must verify it before making a product available (Article 12(1)). Where appropriate given the possible risks, the EU responsible person regularly checks that the product complies with Article 9(5), (6) and (7) (Article 16(2)).
Online, Article 19(c) requires the listing to show information allowing identification of the product, including a picture, its type and any other product identifier.
Separately from the number on the product, Article 15(3) says economic operators must, on request, identify any economic operator who supplied them with the product or a part, component or embedded software, and any economic operator to whom they supplied the product.
Article 15(5) says they must be able to present that information for six years after being supplied with, or supplying, the product.
Article 18 lets the Commission set up a traceability system for certain products, categories or groups of products likely to present a serious risk, by delegated act. Such a system can involve collecting and storing data and placing a data carrier on the product, its packaging or accompanying documents.
It applies only to the products a delegated act under Article 18(3) designates. If your product is not in such a designated category, Article 18 adds nothing to the Article 9(5) identifier.
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You need a type, batch or serial number or other element enabling identification (Article 9(5)). A batch number is one option, not a requirement in itself.
The Commission's guidelines give a barcode as an example of an "other element". Whatever you use must enable identification of the product and be easily visible and legible for consumers.
Article 9(5) says that where the size or nature of the product does not allow it, the information goes on the packaging or in an accompanying document.
Article 19(c) requires information allowing identification of the product, including a picture, its type and any other product identifier.
Only if your product falls in a category designated by a Commission delegated act under Article 18(3). Otherwise the Article 9(5) identifier and the Article 15 supply-chain records are the traceability duties that apply.
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