Can I use a QR code to link to safety information?

A QR code alone is not enough

No — a QR code that links to safety information does not suffice as the only route. The mandatory information about warnings and safety instructions must be directly visible in the product offer itself, not only after scanning a code or following a link. On a webshop's product page, this means: the text must be there, accessible within one click, and not hidden behind an extra step the consumer must take first.

Who must provide this information depends on the role in the supply chain. The manufacturer prepares the safety information and is responsible for its accuracy and completeness — and this also applies to a webshop that resells a purchased product under its own name or brand, or substantially modifies it: for this regulation, it counts as a manufacturer, even if nothing was ever produced. A distributor who resells products of another brand does not need to prepare the information itself, but is expected to verify that it is present before the product is offered. A QR code as a substitute for that verification does not solve the problem, for either role.

Why this follows from Article 19

Article 19 of Regulation (EU) 2023/988 requires that product information must be clearly visible in the product offer, and NVWA clarifies this for the Dutch market with the requirement that the information be on the product page itself, in Dutch, and not accessible only through a reference. The same regulation applies directly in all Member States, so the requirement for direct visibility is fixed; what varies is the language in which it must be provided — German in Germany, and Dutch, French or German in Belgium, depending on the language region.