Here is a clarification regarding data carrier placements in part 2 of the unique product identifier criterion, for clearer guidance on how compliance with the criterion is verified.
Products designed to be used in multiple positions
If a product is designed for use in multiple positions, the data carrier may be placed on the side that is considered the bottom of the outer casing. For example, small desktops with a Thin Client form factor can be used either horizontally, resting flat on a surface, or vertically, standing upright.
Products with VESA mounting
The data carrier must not be placed in a location that is not visible when the product is in its default intended operational state. For example, it must not be located inside the VESA mounting point of a display. However, if the product has VESA mounting points but mounting it is not considered its default intended operational state, then the data carrier is allowed to be placed inside the mounting area. An example of this is small form factor desktops that come with VESA mounting points, allowing them to be mounted on the back of a display.
If you have questions, please contact Hannes Mäki.
