Can QR codes replace mandatory markings?

QR codes cannot replace core mandatory physical markings for consumer products in the EU. Current EU regulations dictate that QR codes only supplement physical labels. Essential safety information, warnings, and traceability data must remain directly on the product or packaging.

Core Legal Rules:

• General Product Safety Regulation (GPSR): Requires manufacturer details, postal addresses, and product identifiers to be physically printed offline.
• Chemicals (CLP Regulation): Hazard pictograms and critical safety warnings must stay visible on physical packaging.
• Inclusivity & Access: The European Commission notes that relying exclusively on digital scans discriminates against consumers without smartphones or internet access.

Emerging Digital Exceptions:

• Digital Product Passports (DPP): Under upcoming frameworks like the Ecodesign for Sustainable Products Regulation (ESPR), QR codes are mandatory for lifecycle, material, and recycling data, but they live alongside physical compliance stamps.
• Sector-Specific e-Labels: Certain exemptions exist (such as specific nutritional or ingredient data for wine), but critical safety warnings remain non-negotiable.