Can I use a QR code instead of printed information for GPSR labeling?

A QR code can support GPSR labelling, but it usually cannot replace the mandatory information that must be physically provided. Under the General Product Safety Regulation (EU) 2023/988 (GPSR), key safety and traceability details must appear on the product, its packaging, or an accompanying document, depending on what is feasible. A QR code works best as an additional channel for manuals, translations, and extended safety content, while the required label text remains printed and readable.

Can a QR code replace printed GPSR label information?

In most cases, a QR code does not replace mandatory GPSR label information. GPSR requires certain safety and traceability information to be provided in a way that is available at the point of use, typically on the product itself, on the packaging, or in an accompanying document when the product’s size or nature makes on-product marking impractical.

A QR code can be added as a helpful supplement, for example, to provide longer instructions or versions in multiple languages. However, if a specific piece of information is required to be physically present, a digital link alone is not equivalent. The exact content and placement can also be affected by any applicable EU harmonisation legislation for the product (for example, sector-specific rules that impose their own marking and instruction requirements).

What information must be physically on the product or packaging under GPSR?

GPSR focuses on traceability and consumer safety information, and it expects clear identification and contact details to be physically provided. What must appear where follows a practical hierarchy: on the product when feasible; otherwise on the packaging; otherwise in an accompanying document supplied with the product.

Typical elements that should be physically provided

Product identification: a model, type, or other identifier that allows the product to be clearly matched to documentation and listings.
Batch or serial number: where applicable, to support traceability.
Manufacturer identification and contact details: the manufacturer’s name and postal address, plus an electronic contact address that enables direct two-way communication (for example, an email address or contact form).
EU Responsible Person details (when required): the name and contact details of the EU-based economic operator fulfilling the Responsible Person role, provided on the product, packaging, or accompanying document, depending on feasibility.
Required warnings and safety information: visible, durable, and in the official language(s) of the destination Member State(s), as applicable to the product and its foreseeable use.

Practical rules that affect placement

Legibility and permanence: information should be readable without magnification and remain available through normal handling.
Small items: if the product is too small or marking is impractical, move the information to the packaging, then to an accompanying document.
Language: warnings and safety instructions must be in the required language(s) for the markets where the product is made available.

How should a QR code be used compliantly for GPSR information?

Use a QR code to add information, not to hide required information. A compliant approach is to keep all mandatory label elements physically present, then use the QR code for content that benefits from being longer, multilingual, or easier to update without changing the required label text.

Good uses of a QR code under GPSR

Digital user manuals and installation guides.
Safety instructions and warnings in additional EU languages (while still providing the required languages in the physical materials).
Care, maintenance, and troubleshooting information.
Optional product registration pages for consumers that do not block access to safety information.

QR code compliance checklist

Do not rely on the QR code for mandatory label text that must be on the product, packaging, or accompanying document.
Keep the destination stable (avoid frequently changing URLs) and maintain it for the product’s expected lifetime.
Ensure access is free and direct: no paywall and no required login to view safety information.
Plan for offline reality: include essential safety instructions in print, because consumers and inspectors may not have connectivity.
Avoid using dynamic content to change the meaning of required safety information after sale; use updates to add clarity, not to replace what should have been provided physically.

How does EARP help with GPSR labelling compliance?

We help you implement GPSR labelling that works in real marketplace and authority checks, without guessing what can be digital and what must be printed. Our support is practical and documentation-focused, so you can keep listings and shipments aligned with EU expectations.

Label and packaging content review against GPSR traceability and safety information expectations
Formatting and placement guidance for EU Responsible Person contact details
Checks for consistency between product identifiers, label text, and your supporting documentation
Document storage and readiness support for market surveillance information requests

See our GPSR compliance services, or contact us to review your labelling and QR code approach before it creates listing or enforcement issues.