GPSR traceability: batch, serial and type numbers

The requirement, word for word

Manufacturers shall ensure that their products bear a type, batch or serial number or other element enabling the identification of the product and which is easily visible and legible for consumers, or, where the size or nature of the product does not allow it, that the required information is provided on the packaging or in a document accompanying the product.

The list, "type, batch or serial number or other element enabling the identification of the product," is open-ended by design. GPSR does not mandate one specific numbering scheme. The only firm test in the text is whether the marking enables the product to be identified, not which format the number takes.

Where it has to go

1. 1

   On the product itself

   The default location. It has to be easily visible and legible to consumers, not hidden or printed too small to read.

2. 2

   On the packaging, only if the product's size or nature prevents marking the product

   This is a fallback, not a free choice. It applies only where physically marking the product itself is not possible.

3. 3

   In an accompanying document, as a last resort

   Used when neither the product nor the packaging can carry the mark.

Article 9(5) sets this as a strict priority order, not three equally valid options. A seller cannot choose "accompanying document" for convenience if the product could reasonably carry the mark itself.

Is a plain Amazon SKU enough?

How this differs from the Article 19 listing disclosure

Article 9(5) is a physical marking duty on the manufacturer's product or packaging. Article 19(c) is a separate, online-listing duty requiring "information allowing the identification of the product, including a picture of it, its type and any other product identifier" to appear in the offer itself. The same identifier can satisfy both, but they are two different checklists. See GPSR Article 19 explained for the listing side.

The technical documentation behind the number

Article 9(2) requires manufacturers to draw up technical documentation before placing a product on the market, and to keep it current and available to market surveillance authorities.

Manufacturers shall ensure that the technical documentation referred to in paragraph 2 is up to date. They shall keep that documentation at the disposal of the market surveillance authorities for a period of 10 years after the product has been placed on the market and make that documentation available to those authorities upon request.

Ten years is the retention period stated in the regulation itself for this technical documentation. We are not stating a separate retention figure for traceability records specifically, because the research behind this guide did not find one in the primary text distinct from the 10-year technical documentation period.

A stricter regime the Commission could add later

Article 18 allows the Commission to impose a more prescriptive electronic traceability system, specific data carriers and fields, for specific product categories identified as high risk, through a delegated act. This is a discretionary mechanism for the future, not a current blanket requirement, and we did not verify whether any such delegated act has been adopted for general product categories as of this guide's publication date.