Overview

This article explains how to add a QR code to product packaging or labelling that allows a consumer to scan and access product instructions in multiple languages, as part of the Digital Product Passport (DPP) rollout.

⚠️ Important compliance note before you start A QR code can supplement printed instructions and reduce how much translated text needs to be physically printed on pack. It cannot fully replace legally mandatory safety information, warnings, or instructions.

Under the EU General Product Safety Regulation (GPSR, Article 21) and current UK labelling guidance, digital/e-labelling (including QR codes) is treated as supplementary only. Mandatory safety-critical content — for example choking hazard warnings, dosage/usage warnings, or other information required by product-specific legislation — must still appear physically on the product, its packaging, or an accompanying document, in the required language(s) for the market it's sold in.

This means: "remove the instructions from the label and rely solely on a QR code" is not a safe compliance position on its own. Which specific content can move to digital-only, and which must stay physical, depends on the product category (toys, cosmetics, electronics, food, etc.) and must be confirmed with Compliancenon a per-product basis before implementation.

The process below is written on that basis: QR codes are used to extend language coverage and reduce on-pack translation volume, not to eliminate the translation or physical-labelling requirement entirely.

When to Use This Process

Use a multi-language instruction QR code when:

• The product is sold into multiple markets with different required languages.
• On-pack space is limited and cannot fit all required languages legibly.
• You want to provide additional detail (e.g. full manuals, videos, extended usage guidance) beyond the minimum legally required on-pack text.
• The product already has, or is being onboarded to, a Digital Product Passport record.

Do not use this process to remove content that has been confirmed by Compliance as a mandatory physical labelling requirement for that product category.

Step-by-Step Process

Before designing anything, Compliance must confirm, per product/category:

• Which instructions, warnings, or safety information are legally required to remain printed on the product/packaging.
• Which content can be moved to a digital-only format.
• Which languages are legally required on the physical label for each target market.

Document this decision per SKU or product family — it will differ by category (e.g. toys, cosmetics, electricals, food/supplements).

• Translate the full instructions into all required languages for the markets the product is sold in.
• Structure content so it can be linked to the product's Digital Product Passport record (per DPP data requirements — product identity, batch/serial reference, and the relevant instruction set).
• Have translations checked by a qualified translator/reviewer for the product category (technical/safety translations often need domain-specific review, not just linguistic).

• Host the multi-language instructions on a publicly accessible page (or within the DPP platform record) with no login required.
• Ensure the destination page is mobile-friendly and lets the user select their language (auto-detect by phone locale where possible, with manual override).
• Include the mandatory physical-label content on the digital page too, for completeness, even where it's duplicated from print.

• Generate a static QR code per SKU (or a DPP-linked dynamic code if using a DPP platform that manages redirects centrally).
• Test scanning on multiple devices/OS versions and confirm the destination loads correctly and quickly.
• Confirm the code meets minimum size and contrast requirements for reliable scanning at expected packaging print size (generally at least 2 cm x 2 cm, with a quiet zone/margin around it).

Add a short, multi-language header directing consumers to scan, positioned clearly next to the QR code. Example wording set:

Note: this header should describe the QR code as providing additional or translated instructions — not imply it is the only source of instructions, if physical instructions are also legally required to remain on-pack for that market.

• Submit final pack artwork (QR code, header, and remaining physical text) to Compliance for sign-off before print.
• Confirm the artwork still carries all content identified as mandatory in Step 1.
• Retain a compliance file recording the Step 1 decision, translations used, and QR destination content, in case of regulatory query.

• Roll out updated packaging.
• Monitor scan analytics (if available via the DPP platform) to confirm consumers are using the QR code as intended.
• Set a review point (e.g. annually, or on regulatory change) to re-confirm the mandatory physical content list is still accurate, as UK and EU digital labelling rules are actively evolving.

Roles and Responsibilities

Key Takeaways

• QR codes extend language coverage; they do not remove the obligation to provide mandatory safety/instruction content physically, in the required language(s).
• Always get category-specific Compliance confirmation before removing any content from physical packaging.
• Keep a compliance record of what was moved to digital and why.
• Revisit this process periodically, as UK and EU digital/e-labelling regulation is subject to ongoing change.