compliance

DPP QR Codes on Product Labels: URL, GTIN and Label Rules

What to put in a DPP QR code, where it should point, how GTIN/GS1 URLs fit, and why the QR code is only the access layer.

3/6/2026 · 8 min read · InfoDPP

Editorial update, 16 July 2026: the references to EN 18219 and EN 18220 (together with four other horizontal DPP standards) are now in the Official Journal through Decision (EU) 2026/1736. The Decision does not make QR codes mandatory in every sector or replace sector-specific placement and format rules for the data carrier. What the Decision covers →

Battery implementation, reviewed on 9 October 2026. The Registry user guide v1.03 of 16 September specifies an https product identifier in JTC 24 format, with a limit of 2000 characters. The identifier encoded in the carrier and the registration data must agree. The guide’s statement about a missing battery semantic catalogue describes that version, not live availability today. The 30 September webinar announced further battery specifications. Registry User Guide v1.03.

Why QR Codes Matter in DPP Projects

For most manufacturers, the visible part of a Digital Product Passport project is a data carrier, often a QR code. Depending on the applicable sector rules, that carrier may be on the product, an affixed label, the packaging or accompanying documentation.

But one regulatory distinction is critical:

A QR code is a data carrier, not the whole Digital Product Passport.

That means putting a QR code on a product is not, by itself, the same thing as completing the full DPP obligation. The code must point to a working digital record, backed by the right identifier and the required product data.

What the Law Requires

Under ESPR and the relevant sector-specific rules, distinguish the following:

the product may need a data carrier,
the data carrier must connect to the relevant digital information,
the DPP itself is the structured digital record behind that access layer.

So when companies ask, “Do we just need a QR code?”, the correct answer is usually: no, not just a QR code.

A QR code provides access to the passport. You also need to decide how to assign product identifiers, check data quality and store the data. Make clear who is responsible for updates.

What a Good DPP QR Setup Looks Like

A practical implementation usually has four parts:

The identifier: for example GTIN, plus batch or serial data where needed
The URL: the link encoded in the QR code
The resolver or landing endpoint: the web address that serves or routes the request
The passport data: the actual digital product information behind the link

If one of these parts is missing, a successful scan may still fail to provide the required passport information.

The Data-Carrier Standards (EN 18220 / EN 18219)

EN 18220 covers data carriers and EN 18219 unique identifiers; their references were published under Decision (EU) 2026/1736.

A separate proposal changes the battery references

The 30 September webinar for batteries, slide 8, describes a draft delegated act that would update Article 77(3) to EN 18220:2026 for QR codes and EN 18219:2026 for unique identifiers, or equivalent standards. The presentation reports publication of the draft for feedback on 29 September and envisages adoption and publication in 2027. Those dates describe a proposal and a plan, not an amendment already in force.

The draft is part of an act on industrial battery performance and durability, but the proposed change concerns the identification provision for battery passports. It should not be read as a new passport obligation only for industrial batteries or as a change to every product passport. Article 77(3) currently refers to the ISO/IEC 15459 series or equivalent standards.

In battery specifications and supplier contracts, distinguish the standards referenced by the current rules from the references proposed in the draft amendment. The presumption of conformity under Decision (EU) 2026/1736 applies only to the ESPR requirements covered by those standards. The Decision does not amend the Batteries Regulation.

Where the QR Code Should Point

In most modern implementations, the QR code points to a URL, for example:

https://resolver.example.com/01/05901234123457

That URL can then lead to:

a consumer-facing passport page,
a machine-readable data response,
or a resolver that decides which view or data format to return.

This is one reason URL architecture matters so much in DPP planning: once the code is printed on packaging, changing the link later is costly.

Practical Label Rules for 2026

The exact sectoral rules may differ, but manufacturers preparing DPP labels in 2026 should already use these practical checks:

1. Make the code scannable in real conditions

The QR code should remain readable in the environments where the product is sold, used, repaired, or sorted for recycling.

Check at least:

print contrast
physical size
quiet zone (the clear margin around the code)
curved vs flat surface placement
scan reliability with ordinary smartphones

2. Use a durable placement

A DPP access code should not disappear after minimal wear if it needs to remain accessible for a longer period.

Think about:

abrasion
moisture
heat
folding or creasing
surface material compatibility

3. Avoid unstable URLs

Do not print experimental links that may be replaced after launch. The printed code should use a stable URL strategy from day one.

4. Test across stakeholders

A code that scans in the design office may still fail in warehouses, stores, service centres, or after transport.

Product, Packaging or Documentation?

The legally correct placement may depend on the applicable product rules, but when planning implementation there are usually four options:

on the product itself: best for long-term accessibility where physically possible
on an affixed label: useful when the product surface is unsuitable but the label remains with the product
on packaging: easier to print, but may be lost after purchase or disposal
on accompanying documentation: useful as a fallback, but less convenient in many real-world situations

The right answer is product-category specific. Do not generalise one placement rule across every sector.

Common Mistakes Manufacturers Make

Mistake 1: treating QR as the whole compliance project

A QR code without a reliable backend record is only a doorway with nothing behind it.

Mistake 2: using a short-term campaign URL

Marketing URLs change. Printed compliance links should be designed for continuity.

Mistake 3: ignoring identifier structure

If the URL does not reflect a stable product identifier model, future scaling becomes difficult.

Mistake 4: printing before testing

Even small print, laminate, contrast, or placement issues can break scan performance.

Mistake 5: assuming one label approach fits all markets

Language, packaging practices, and product handling conditions may differ by market and by sector.

What to Test Before Printing at Scale

Before approving a full label run, test:

scan speed on iPhone and Android devices
readability in bright and low-light conditions
scanning after transport wear
whether the URL opens correctly every time
whether the destination page contains the intended passport information
whether batch or serial logic works correctly where applicable

Correcting the code is much easier before labels are printed and distributed.

A Safe 2026 Workflow

You can organise the label work in the following order:

define the identifier structure
create the passport record or pilot record
generate the final URL
test the QR code in real print conditions
approve label artwork only after technical validation
document who owns future updates to the destination data

That sequence reduces the risk of launching a code that looks correct but fails in use.

QR Code vs Full DPP Obligation

This is the key compliance takeaway:

QR code = visible data carrier
URL = access path
digital record = passport content
governance = compliance maintenance over time

You need the whole chain, not just the square on the label.

Official Sources

Want to see how a product passport works when someone scans its QR code? Try OriginPass.eu and create an example for your product.

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