No, a QR code alone is not sufficient for the safety warnings that GPSR mandates. The regulation assumes that essential safety information is directly available at the moment a consumer views or uses the product, without first requiring a phone, internet connection, or additional action. A link or code can unlock supplementary information, but may not replace the core of the warning.
This is precisely the detail that many webshops encounter when they have their label or packaging designed: it seems practical to save space by placing everything behind a single QR code, while supervisory authorities and the regulation itself proceed on the basis of direct readability of certain key information on the product or packaging itself.
Why a link is not a replacement for warnings on the product itself
The thinking behind GPSR is that a consumer must be able to assess a risk at the moment he has the product in his hands, even without a smartphone, without reception, and without him taking the trouble to scan a code. A QR code assumes three things that do not always apply: that there is an internet connection, that the destination page remains available, and that the consumer takes the trouble to scan before using the product. Supervisory authorities assess product information based on what is factually directly visible and legible, not what is hidden behind a link.
There is also a practical point: a QR code can point to a page that is later modified, removed, or temporarily offline. Warnings that are unlocked only in this way are then no longer available at the moment when it matters. Direct, permanent information on the label or packaging is more robust in that respect than a reference.
What must be on the label or packaging
The regulation distinguishes between general identification data, such as the name and contact details of the manufacturer and, where applicable, the EU responsible business, and product-specific safety information such as warnings, restrictions on use, and, depending on the product type, type and batch numbers by which a product is traceable. This basic information must appear in the language or languages of the country where the product is offered, directly on the product, packaging, or accompanying document.
How extensive that information must be depends on the product and the risk reasonably associated with it; a simple household item requires less text than a product with an electrical component or a product intended for children. What is precisely expected in this regard is not the same for every product, and that is also why a general checklist rarely fits exactly to one specific item.
Where a QR code can help
This does not mean that a QR code is redundant. For detailed instructions for use, technical specifications, safety data sheets, or a complete manual in multiple languages, a code to an online page is a practical supplement, especially when physical space on the label is limited. The code then serves as an extension of information already directly visible, not as a replacement for it.
The rule of thumb that many businesses follow is that everything a consumer needs in order to use the product safely without an extra step must be legible, while everything that is background information or extra detail may be behind a code. Where that line is drawn precisely varies by product and is something for which you need the risk assessment of that specific item.
What this means for your product page
The same principle applies on the webshop itself: the required information must appear on the product page itself, not solely in a separate document or behind an external link. how required information is structured on a product page shows which components belong to it and how they relate to what appears on the physical label. Because the precise implementation differs depending on your role in the supply chain, the first thing that needs to be clear is which role your company actually has; that is determinable in a few questions.
Because these kinds of subjects work out slightly differently for each product category, we have detailed what is customary for each situation and where the source can be found in the official text. how that information is structured shows where it comes from, and with what the subscription exactly adds you see what else is possible if you want to document it per article.
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