EU Label Compliance

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QR codes on product labels: what they can legally do, and what they cannot

A QR code is a convenience for the consumer and, done properly, an insurance policy for the seller. It is never a substitute for printed text.

Example of the label this guide describes
Fac-simile of the file we deliver. Specimen data, invented company.

Complement, not replace

Under the GPSR a data carrier can complement the mandatory information. The manufacturer's identity, the responsible person, the batch and the warnings stay printed and legible on the product or its packaging.

The same is true for cosmetics today, and the direction of travel elsewhere — packaging, batteries, ecodesign — is towards digital carriers that add data rather than remove ink.

What a permanent code solves

A printed label freezes information on the day of the print run. Addresses change, responsible persons change, warnings are added after a complaint. Every label already in circulation becomes wrong at once.

A permanent code printed beside the QR points at a record you can update. The scan shows today's data, dated, and the labels in the warehouse stay usable.

What the public record shows

Only what legally has to appear on the label: manufacturer, responsible person, product identifier, warnings and the date of the last update. Not your account, your VAT number or your payment history.

It says plainly that it documents client-supplied data on a date and is not a government certification, because claiming otherwise would be a bigger risk than the problem it solves.

Printing the code

We place the QR at a size that survives a supermarket scanner and a worn label, with a quiet zone, and we print the code in human-readable characters underneath so it works when the print is damaged.

Where digital carriers are becoming mandatory

The packaging regulation introduces digital marking for packaging identification on its own timetable. The battery regulation brings a battery passport for certain categories. Ecodesign rules bring the digital product passport for others.

None of these removes the printed safety blocks. They add a machine-readable layer with its own data model and its own deadlines, and they will arrive category by category rather than all at once.

Designing a code that survives

Print size, quiet zone, contrast and substrate decide whether a scan works after six months in a warehouse. A code printed too small on a curved surface fails at the first attempt, and consumers do not try twice.

We size the code for the label, keep the quiet zone clear and print the human-readable characters underneath, so a worn code is still usable by typing it.

What not to put behind the code

Marketing pages, trackers and login walls. Where a data carrier carries regulated information it has to be accessible without an account, without an app and without collecting data about the person scanning.

Our record pages are plain, fast and public, and they say what they are: a dated statement of client-supplied data, not a certification.

Carrier rules, today

FrameworkCarrier allowedReplaces printed text?
GPSRYes, as a complementNo
Cosmetics 1223/2009LimitedNo
Packaging (PPWR)Required on its own timetablePartly, for identification
BatteriesBattery passport for some categoriesNo, adds
Ecodesign (ESPR)Digital product passport, by categoryNo, adds

How the pieces fit

The same information, in the order an inspector or a reviewer meets it.

Carrier rules, today1GPSR2Cosmetics 1223/20093Packaging (PPWR)4Batteries5Ecodesign (ESPR)

Words that keep coming up

Quiet zone
The empty margin around a code that a scanner needs.
Data carrier
A machine-readable symbol such as a QR code or a GS1 Digital Link.
Digital product passport
A structured data record linked to a product under the ecodesign framework.
Human-readable interpretation
The characters printed under a code so it can be used without scanning.

Questions people ask

Does the code expire?

The code does not. The record stops resolving if the subscription ends, and we keep the data for thirty days.

Can I use my own QR?

Yes, for your own content. The compliance record needs its own code so that the data behind it is the data we maintain.

Is a QR mandatory anywhere yet?

Not for the general product safety blocks. Packaging and several sector rules are moving that way with their own timetables.

Does the code track who scans it?

No. The record pages set no profiling cookies and do not identify the person scanning.

Can one code cover a whole product range?

No. One code per product is what makes the record meaningful.

What happens if your site is down?

The printed blocks still carry the mandatory information, which is exactly why the carrier complements them.

Related guides

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