Can a QR Code Replace the GPSR Label? What Digital Labels Can and Cannot Do

The short answer: Article 21 allows digital information only in addition

Many sellers would like to move the manufacturer address, Responsible Person details and manual online and leave only a QR code on the box. The GPSR addresses this in Article 21, 'Information in electronic format':

Without prejudice to Article 9(5), (6) and (7), Article 11(3) and Article 16(3), and the relevant provisions of Union harmonisation legislation, economic operators may additionally make the information referred to in those provisions available in a digital format by means of electronic technical solutions clearly visible on the product or, where that is not possible, on its packaging or in a document accompanying the product.

The article goes on to require that the digital information is in a language easily understood by consumers, as determined by the Member State where the product is sold, including in accessible formats for persons with disabilities. Recital 32 says the same thing in plain terms: identification, operator details, instructions and safety information 'could in addition' be provided digitally, such as through a QR or data matrix code. Nothing in the listed provisions is waived.

Article 21 sits in Section 2 of Chapter III. Under Article 2(1), CE-marked products (toys, electrical and radio equipment and so on) are exempt from Section 1 (Articles 9–18) but not from Section 2, and the Commission's business guidelines (C/2025/6233; guidelines are interpretation, not the law) list the provisions on information in electronic format among those that apply to such products. Whether a CE-marked product may provide its instructions digitally, however, is decided first by its own sector legislation, which Article 21 expressly preserves.

What must stay physical

The provisions named in Article 21 give you the list of information that a QR code cannot replace:

Could a web page count as the 'accompanying document'? The structure of the text says no: Article 21 treats digital provision as a separate, additional route and requires the code itself to sit on the product, packaging or accompanying document, so the accompanying document is a physical item that travels with the product, such as a leaflet, hang tag or warranty card. That is our reading of the text; the Commission's guidelines do not discuss Article 21 in more detail.

The same logic applies online. Article 19 requires the offer itself to show the manufacturer, the Responsible Person, product identification and warnings 'clearly and visibly'. A QR code or an external link on the product page does not meet that; see online selling requirements.

Why 'scan for instructions' does not work under the GPSR

Article 9(7) requires the product to be 'accompanied by' clear instructions and safety information, Article 11(4) puts the same duty on importers, and Article 21 lists Article 9(7) among the provisions that may only be supplemented digitally. For products governed directly by the GPSR, such as cots, children's clothing or most non-electrical household goods, a printed leaflet or on-pack warnings cannot currently be dropped.

The reasons are practical: not everyone has a phone or connection, links break, and inspectors check the physical product. Wording and translation of warnings are covered in warning language rules.

Two exceptions are often confused with 'digital is fine':

• Products that are safe without instructions: the second sentence of Article 9(7) removes the duty altogether. That means none are needed, not that they may live online.
• CE-marked products follow their sector law: the new Machinery Regulation (EU) 2023/1230, applying from 14 January 2027, allows instructions for use in digital format (Article 10(7)). The machine must say how to access them, a free paper copy must be supplied within one month if the user asks at the time of purchase, and for machinery that non-professional users are intended or likely to use, the safety information essential for putting it into service and using it safely must still be on paper.

Other EU laws: where digital labels are required or allowed

EU product law is moving towards digital labels, but each law has its own scope and dates, and almost all keep a physical core (dates checked against the Official Journal texts):

• A mandatory QR code is not permission to have only a QR code. The battery QR code and the toy DPP add a layer on top of existing labels.
• The ESPR does not by itself require a DPP for your product. A product group needs one only once a delegated act covering it has been adopted and applies. Check the Commission's current list for your category (to be re-checked).
• A horizontal 'digital instructions' reform is still in the legislative process. The Commission's 2025 digitalisation omnibus proposal (often called Omnibus IV) would relax paper-instruction rules in several CE-marking laws. At the date of checking we could not confirm its publication in the Official Journal (to be re-checked). Do not design packaging around a draft.

More on the toy DPP in the toys white paper and on battery label dates in the electronics white paper.

What a QR code is good for

As a supplement, a QR code is genuinely useful, especially for multi-country sellers:

• Full multilingual manuals: print the warnings and key instructions in the languages of your countries of sale, and link to every language version online for buyers in other markets.
• Updated safety information: printed packaging cannot change, a web page can. Adding a new usage warning online is helpful, but it does not replace corrective action and notification duties such as those in Article 9(8).
• Recalls and safety warnings: where not all affected consumers can be contacted directly, Article 35(4) requires recall notices and safety warnings to be spread through other channels, including the company's website. A product safety page behind the code is a natural place for them. Article 36 sets out what a recall notice must contain; see accidents and recalls.
• Product registration: if you collect contact details through a scan-to-register page, Article 35(2) requires an option to give separate contact details for safety purposes only, limited to the minimum and used only for recalls or safety warnings.
• Complaints and accident reports: Article 9(11) requires manufacturers to publish channels such as a telephone number, electronic address or dedicated website section. A code that opens that section is convenient, but the electronic address on the label must still be printed as text.
• Assembly videos, care instructions, declarations: extras that reduce misuse.

Whatever legally required information you put behind the code must itself comply: Article 21 requires the language of the Member State of sale and accessible formats.

Making a QR code last

Article 21 sets no retention period for the linked page, but other laws give a useful benchmark: the Machinery Regulation requires digital instructions to stay online for the expected lifetime of the product and at least 10 years after placing on the market, and the toy DPP and detergent digital label must also remain available for 10 years. Plan along those lines:

• Use a domain you control, for example https://yourbrand.example/p/EX-1000. Avoid subscription 'dynamic QR' redirect services: when the plan lapses, the code dies, and printed packaging cannot be fixed.
• Keep URLs stable: one fixed path per model (and per batch where it matters), permanent redirects when the site is rebuilt, and never a campaign page or file-sharing link.
• Print a short URL next to the code so people who cannot scan can type it.
• No login, no app: the safety information should open straight away. The fertilising-products rules (new Article 11b inserted by Regulation 2024/2516) explicitly require digital labels to be accessible without prior registration, app downloads or passwords, which is good practice for everyone.
• Let users choose the language rather than locking it to their location.
• Keep tracking minimal: Article 19(2) of the Detergents Regulation bans tracking beyond what is strictly needed for digital labels. Elsewhere too, keep marketing trackers off safety pages; the GDPR applies.
• Print quality: enough quiet zone, contrast and size, tested on the real packaging material; the code must survive transport and use like the rest of the label.
• Archive every version of the page with its publication date, alongside the technical documentation, so you can show which information went with which batch.

Packaging layout: physical block plus code

A practical layout puts the complete GPSR information block on one panel of the packaging, with the QR code beside it and a short line explaining what it is for, such as 'More languages / safety updates'. The fields and example values are in GPSR label requirements, and you can draft the text block with the GPSR label generator before adding your own code.

• Information block: type/batch, manufacturer name, postal and electronic address, EU Responsible Person name, postal and electronic address, importer if any.
• Warnings: printed in the languages of the countries of sale on the pack or leaflet; the code adds detail only.
• Codes required by other laws, such as the battery QR code from 2027, follow those laws' rules on content and placement; keep them separate from marketing codes. The toy regulation even requires other information to be clearly separated from the DPP data (Article 19(10)).
• Marketplaces review product and packaging photos, so the information block must be legible in your images; a photo that shows only a QR code proves nothing.

Not sure which laws apply to your product? Start with the three-step compliance check.