No. However, the GS1 version of Data Matrix, GS1 DataMatrix, always requires the use of the Function 1 (FNC1), both as the first character in the data string and as a data separator after any non-predefined length element strings.
ISO/IEC Data Matrix may be used outside the GS1 System, and the proper use of the Function FNC1 character allows a scanning system to distinguish between the two versions (ISO/IEC DataMatrix versus GS1 DataMatrix).
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