The most common mistake with type and batch numbers is not that they are missing from the product itself, but that the link to the online information is incorrect. A number is on the box or label, but the product page shows a different number, an outdated version, or nothing that refers to that specific type or batch. As a result, a product is marked, but not traceable — and traceability is precisely what this obligation is about.
The solution is not an extra sticker, but a fixed procedure: each type or batch gets one number, that number appears both on the product and on the corresponding product page, and with each change in the batch, that link is checked again. This sounds straightforward, but in practice it is precisely the step that is skipped when a webshop quickly switches between suppliers or batches.
Why traceability is the heart of the rule
A type or batch number has only one function: in case of a complaint, incident, or recall, to quickly determine which units are affected and which are not. If that link does not work, you lose that distinction precisely when you need it. A supervisor or a customer who asks for the number must find something — a number that does not refer to anything is in practice the same as no number.
Where it goes wrong in practice
One number for the entire assortment
Some webshops use one general article number, the same for all deliveries of a product, even if the composition or supplier changes in the meantime. That number then identifies a product line, not a specific batch. In a recall that affects only one delivery, that distinction can no longer be made.
On the box, not online
The number is correct on the packaging, but the product page does not display it, or displays a different number that was copied when the page was created and has never been updated. For the customer and for a supervisor, what is online counts just as much as what is on the box.
Batch number changes, product page does not
A supplier delivers a new batch with a different number, but the existing product page remains unchanged because no one has assigned that link as a recurring task. After a few months, there is a number online that does not match any batch in the warehouse anymore.
What the regulation asks for on this point
The regulation requires that a product is identifiable by a type, batch or serial number, or by another element that allows identification, and that this identification is also part of the information for the consumer. How you organize this is up to you; that it is correct and remains up to date is what supervisors look at. The precise wording and full scope of this obligation can be found on EUR-Lex; we do not state here whether a specific arrangement complies with it.
How to fix it
The most practical approach is a fixed moment in the purchasing process where the type or batch number is recorded, linked to the corresponding product page, and checked with each new delivery. For companies with multiple variants or suppliers, it is clearer to track this per article rather than per product line. consult the knowledge base for more on labelling and identification provides a broader picture of what else should be on a label and a product page.
Anyone unsure whether this is relevant for their own assortment — for example because products are resold without modification — would do well to first clarify their own role in the chain, as that determines who is responsible for this link. in a few questions see which role applies to you gives an initial indication, free of charge and without obligation.
What this does not mean
This obligation does not mean that each individual unit requires a unique serial number; identification is needed at the level of type or batch, unless the nature of the product requires otherwise. Nor does it mean that you need to rebuild the entire product page with every minor change in your records — only the identifying number must be correct and traceable online.
Structuring this link per product, together with the rest of the product file, is precisely what the paid part of view the system and pricing helps with: the fixed location where type or batch number, risk assessment and technical documentation are kept together. If you are still unsure whether this applies to your products, first check frequently asked questions on labelling and identification.
Do you want to know whether and how this obligation applies to your products? Take the free quick-scan or browse the topics in the knowledge base — no account required, no obligation.