Do I have to put a batch number on my products?

An identification number is mandatory for anyone who qualifies as a manufacturer

A manufacturer is required to provide a product with a model, batch, or serial number, or another element by which the product can be identified. That number should primarily be affixed to the product itself. If this is not possible due to the product's shape or nature, the information may be placed on the packaging or in an accompanying document. The objective is always the same: in the event of a complaint, an accident, or a recall, it must be possible to trace which specific batch or production series is involved.

Who qualifies as a manufacturer under this rule is broader than most entrepreneurs think. Not only whoever manufactures the product itself, but also whoever places it on the market under their own name or brand — including the online retailer that merely affixes its own logo to a purchased product — bears this obligation. A distributor who resells products from a manufacturer or importer without placing them under their own name is not required to apply a batch or serial number themselves; however, that role does require verification that the information is present before the product is offered for sale, but not to add it themselves.

Where this obligation stems from: Article 9 of the regulation

This obligation is set out in Article 9 of Regulation (EU) 2023/988, which governs the identification of products and economic operators. The article links the identification requirement to the manufacturer and the role that flows from it, and leaves the precise form — model, batch, or serial number — open, as long as the product can be traced with it. Because the GPSR is a regulation, this provision has applied directly and uniformly in all twenty-seven Member States since 13 December 2024; there is no national transposition that changes anything about it.