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QR codes under the EU General Product Safety Regulation

The GPSR mentions QR codes, but as an addition to the information that travels with a product, not as a replacement. Here is what has to be on the product, the package or the paper in the box, and what you can move online.

Last reviewed
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6 min read
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General information, not legal advice

What the GPSR is

Regulation (EU) 2023/988, the General Product Safety Regulation (GPSR), sets the baseline safety rules for consumer products sold in the EU, online and offline. It replaced the General Product Safety Directive and has applied since 13 December 2024. It applies to products where no more specific EU safety rule covers the same risk or obligation, so it is the default for a wide range of everyday goods.

What must accompany the product

Article 9 sets out what manufacturers must ensure. Three paragraphs matter for labels and documentation:

Table — Regulation (EU) 2023/988, Article 9
ParagraphWhat is requiredWhere it goes
9(5) IdentificationA type, batch or serial number or another element that identifies the product.On the product; where its size or nature doesn’t allow it, on the packaging or in an accompanying document.
9(6) ManufacturerName, registered trade name or trade mark, and postal and electronic address.On the product; otherwise on the packaging or in a document accompanying the product.
9(7) Instructions and safety informationClear instructions and safety information in a language consumers can easily understand, as determined by the Member State where the product is sold.Accompanying the product. Not required where the product can be used safely as intended without them.

The operative text speaks of information that is on the product or accompanies it. Compliance guides published since the Regulation took effect read this consistently: safety warnings and instructions needed for safe use must physically travel with the product, and a QR code on its own does not meet the obligation.

What the Regulation says about QR codes

The articles do not mention QR codes. The recitals do: recital 32 says that identification information, instructions and safety information could in addition be provided in digital form by means of electronic solutions, such as a QR or data matrix code. The words “in addition” are the point. A code can extend what you provide; it does not stand in for the information that has to accompany the product.

So the practical pattern for consumer products is:

  • Print the identification, the manufacturer details and the safety information and instructions needed for safe use, in the languages of each market.
  • Put behind the code everything that helps the customer beyond that: the full manual, videos, troubleshooting, more languages, spare parts, warranty and support.

Selling online: what the offer must show

Article 19 adds obligations for distance sales. An online offer must clearly show, among other things:

  • the manufacturer’s name, registered trade name or trade mark, and postal and electronic address;
  • where the manufacturer is outside the EU, the details of the responsible person in the EU;
  • information identifying the product, including a picture, its type and any other identifier;
  • any warning or safety information to be affixed to the product or included in the accompanying documents, in a language consumers can easily understand.

A product page with the safety information and the instructions as documents is a convenient single source to link from your listings, but the warnings still need to appear in the offer itself.

What a QR code can usefully add

Once the required information is printed, a QR code is where most of the value is added for the customer and for you:

  • the full instructions, which no longer need to fit in a leaflet;
  • setup and maintenance videos, troubleshooting and FAQs;
  • languages beyond the ones printed in the box;
  • spare parts with part numbers, warranty terms and registration, and support contacts;
  • dated safety notices that reach everyone who scans, including owners who never registered.

That last point is where an updatable page earns its place. If you need to correct a warning or tell owners about a problem, a notice at the top of the page is seen by every customer who scans from that day on, without reprinting anything.

ItemDocs is built for this layer: one permanent page per product behind one QR code, with safety notices, documents and up to ten languages. It does not handle your labelling, your risk assessment or the notifications the GPSR requires from manufacturers when a product is unsafe. See QR codes for product manuals for what to put on the page, and the Machinery Regulation guide if your products are machinery.

Sources

Checked

Links open the original documents.

  1. [1]Regulation (EU) 2023/988 on general product safety: Articles 9, 19 and 52, recital 32EUR-Lex
  2. [2]Labelling instructions for GPSR complianceEAS Project — Secondary compliance guidance.
  3. [3]The General Product Safety Regulation: new guidanceMatheson LLP — Secondary commentary.

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