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Supplier only gives a barcode — what is the manufacturer identifier?

Short answer: If the manufacturer or supplier uses the barcode as its own product identifier, you may report that barcode as the manufacturer identifier (C128) as well as the standardised identifier (C129). The Commission guidance calls this "perfectly acceptable". Record that the supplier confirmed it; do not assume it.

What the guidance says

Section 3.5.4 of the Commission's customs guidance: the manufacturer, producer or product supplier "may decide to assign no NS-PID but use the S-PID also as NS-PID to simplify their operations; this is perfectly acceptable." It also says that where no NS-PID exists at all, the manufacturer or supplier "is expected to assign one", with no specific structure required.

What to do

1. Ask the supplier one question: "Do you use the barcode as your product code, or do you have a separate model / article number?"
2. If they use the barcode: record the barcode in both the manufacturer-code column and the barcode column, and note "supplier uses GTIN as product code, confirmed [date]".
3. If they have a separate code: record that as the manufacturer code.
4. If they have neither: ask them to assign one (any stable reference per variant); the guidance expects them to.

When a barcode is not enough

• The barcode belongs to a different product or packaging level than the one you ship (batch or case codes where a model-level code exists — the guidance treats deliberately unhelpful PIDs as an infringement).
• You copied the barcode from a listing, not from the maker; it may not be theirs.

Source: Commission guidance, section 3.5.4 (PDF, pages 27–28).

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