TL;DR
- Eight product rules in the EU and the US involve a QR code or another data carrier. Only EU wine e-labels and the US bioengineered food disclosure let the code carry mandatory information in place of the printed label, plus a narrow permission for very small packaging.
- The Battery Passport is the first rule that makes the code itself mandatory, from 18 February 2027. Reusable packaging and detergents follow in 2029, other product groups when their EU delegated acts are adopted.
- One standards-based code built on the product's GTIN can serve several of these rules at once, as long as the page behind it meets each rule's conditions.
A QR code is part of product compliance in two different ways. Under some rules it carries mandatory information, so that information can leave the label. Under others it is the required way into a digital record, such as a Digital Product Passport, while the label stays as it is. The table below shows which rule does which, and from when.
Product compliance codes at a glance
| Rules covered | Seven EU regulations and one US disclosure standard |
| Code may replace printed information | EU wine e-labels, the US bioengineered food disclosure, and very small packaging under the PPWR |
| Code is mandatory | Battery Passport from 18 February 2027; reusable packaging under the PPWR from 12 February 2029; detergents from 23 September 2029 |
| Code only adds information | EU food labels under Regulation (EU) No 1169/2011, and US Nutrition Facts |
| Standard named by law | None: the EU requires a standards-based data carrier without naming one technology |
Which rules involve a QR code, and what does each require?
| Rule | What it requires | Can the code carry it, or only add? | Date | Guide |
|---|---|---|---|---|
| EU wine e-labels, Regulation (EU) 2021/2117 | Ingredient list and nutrition declaration for wines and aromatized wines | Carries the ingredient list and the full nutrition declaration as an e-label. The energy value ("E") and allergens stay printed | Wines produced from 8 December 2023 | Wine labeling |
| EU food information, Regulation (EU) No 1169/2011 | Name, ingredients with allergens emphasized, net quantity, date marking, nutrition declaration and the other mandatory particulars, on the label | Adds only: detail, translations, origin | Applies now | Food packaging |
| ESPR, Regulation (EU) 2024/1781 | A Digital Product Passport, connected through a data carrier to a persistent unique product identifier on the product, its packaging or its documents | Required route: the passport is digital, and the carrier leads to it | In force since 18 July 2024; each product group from the date in its delegated act | ESPR |
| Battery Regulation, Regulation (EU) 2023/1542, Article 77 | A Battery Passport for every LMT battery, EV battery and industrial battery over 2 kWh | Required: a QR code on the battery links to the passport through a unique identifier | 18 February 2027 | Battery Passport |
| Construction Products Regulation, Regulation (EU) 2024/3110 | A construction Digital Product Passport for declarations of performance and conformity, safety information and instructions for use | To be set by delegated acts under Chapter X | Applies since 8 January 2026; the passport follows its delegated acts | Construction products |
| Detergents Regulation, Regulation (EU) 2026/405 | A Digital Product Passport, free and without login, available for ten years, plus a digital label | Adds: the physical label stays; passport and digital label are reached through one data carrier on the pack | 23 September 2029 | Detergents |
| PPWR, Regulation (EU) 2025/40 | From 2026: restricted substances, conformity documentation, producer responsibility, minimization. Later: a harmonized material and sorting label | Optional now, for producer information, and may stand in for printed information on very small packaging. Required for reusable packaging from 12 February 2029 | 12 August 2026; harmonized label from 12 August 2028 at the earliest | PPWR |
| US bioengineered food disclosure (USDA) | Disclosure that a food is bioengineered | Carries the disclosure through a scannable link, with the text "Scan here for more food information" and a phone number next to it | Applies now | Food packaging |
Some dates are not yet fixed: the PPWR harmonized label moves later if the Commission's implementing acts arrive late, and ESPR product groups such as textiles, furniture, tires, mattresses, steel and aluminium wait for their delegated acts. Check the rules for your markets with your regulatory adviser before printing.
When can a QR code replace the printed label?
Rarely. Most rules treat the code as an addition to a complete label:
| What the code does | Rules |
|---|---|
| Carries mandatory information in place of the label | Wine e-labels (all but the energy value and allergens); the US bioengineered food disclosure; very small packaging under the PPWR |
| Is the required way into a digital record | Battery Passport; ESPR product groups once their act applies; detergents from 2029; reusable packaging from 2029 |
| Adds to a complete printed label | EU food information; US Nutrition Facts; the detergent label |
| Not yet defined | The construction passport; the PPWR harmonized label; ESPR product groups without an adopted act |
What must the page behind the code do?
A compliant code can still lead to a non-compliant page. Each rule sets its own conditions:
| Rule | Conditions on the page or record |
|---|---|
| Wine e-label | No user tracking, no marketing content, in a language the buyer understands |
| US bioengineered disclosure | The disclosure appears first, without marketing |
| ESPR passport | Open standards; machine-readable, structured and transferable without vendor lock-in; no customer personal data without consent; access set by audience; available for at least the product's expected lifetime |
| Battery Passport | One passport per battery; public data and data reserved for operators and authorities, as set out in Annex XIII |
| Detergent passport | Free of charge, no login, no tracking beyond what is strictly necessary, available for ten years |
How to build a compliance-ready QR code program: seven steps
- Map the rules per product and market. Use the table above to note, for each product, which rules apply and whether each requirement must be printed or may move to the code.
- Keep the mandatory particulars on the label. Decide what the code adds. Where a rule lets information move, as for wine, keep printed what that rule still requires: the energy value and allergens.
- Give every product a persistent identifier. Use the GTIN your barcode already carries, and decide the level: model, batch or item. Batteries need one passport, and one identifier, per unit.
- Use one standards-based code. A GS1 Digital Link QR code writes the GTIN, and optionally the batch or serial number, into a web address, so the same code rings up at a 2D-ready checkout and opens a page on a phone.
- Build each page to its rule's conditions. Keep wine e-labels and US disclosure pages free of marketing and tracking, put promotions on a separate page, and set access levels where a passport has restricted data.
- Assign owners for the data. The ESPR requires passport data to be accurate, complete and up to date, so link each field to the system that holds it and update it when a recipe, formulation or rule changes.
- Test, print and follow the acts. Scan printed proofs on several phones and a 2D checkout scanner, then track the delegated and implementing acts for your product groups, which set the real dates.
Where the Digital Link platform fits
Digital Link, the platform behind this site, creates conformant QR codes from your GTINs, runs the resolver behind them and hosts the pages they open, from product information pages to passports. Codes can carry batch, expiry or serial variants, so a single batch can be switched to a recall notice. Pages can be shown in several languages, and the destination can change without reprinting. The Free plan covers 5 codes.
Create your first compliance QR code
Frequently asked questions
Which product compliance rules require a QR code?
The Battery Regulation requires a QR code on every LMT battery, EV battery and industrial battery over 2 kWh from 18 February 2027. The ESPR, the Detergents Regulation and the PPWR, for reusable packaging, require a data carrier, which for most consumer goods will be a QR code.
Can a QR code replace the ingredient list on a label?
Only for wine in the EU, where the ingredient list and full nutrition declaration can move to an e-label while the energy value and allergens stay printed. Under Regulation (EU) No 1169/2011 and US FDA rules, the ingredient list stays on the pack for other food.
Do food products need a Digital Product Passport?
No. Food is excluded from the ESPR, the regulation behind the passport. Food packaging still falls under the PPWR and can carry a QR code for labeling, traceability and recalls.
Does a compliance data carrier have to be a QR code?
For batteries, yes. Under the ESPR, each delegated act chooses the carrier for its product group, and a Data Matrix or an RFID tag can also qualify.
Can one QR code serve several regulations?
Yes, if it is built on a persistent identifier and the page behind it meets each rule's conditions. The Detergents Regulation expects a single passport and a single carrier where other EU law already requires one for the same product.
Is GS1 Digital Link legally required for compliance?
No law requires it by name. The ESPR requires a data carrier and identifier that follow recognized standards, and GS1 Digital Link is the widely used standard for a code that checkouts and phones can both read.
