Not exactly. The UPN is a term coined by the DOD in the early 1990s and refers to either a GS1 GTIN or a
HIBCC LIC. A UDI includes two segments: a “device identifier” (DI) and a “production identifier” (PI). The
GTIN (“UPN”) can serve as the DI. The other UDI segment, “PI”, is required if PIs appear anywhere on the
device label or package. So if your device label or package includes PI(s), then the UDI for that device
requires not only a GTIN (“UPN”) but also GS1 Application Identifier(s) to represent the PI(s).