New digital labelling requirements for Global Market Access
Don't get caught out by changes to digital labelling requirements which could result in border delays, product seizures and complete market exclusion.
Key facts about digital labelling requirements
As major markets move towards digital traceability and regulatory bodies increasingly require the use of QR codes to host compliance data, digital labelling is now critical to seamless global market access. Failure to anticipate these requirements is increasingly resulting in border delays, product seizures and complete market exclusion.
A global shift in digital labelling requirements
Argentina has led in the use of digital markings to verify product certification in real-time, requiring QR codes for specific product categories. The traditional S Mark for regulated products (electricals and PPE) must now be accompanied by a QR code. These must provide a direct link to the product’s safety credentials, certification status, Declaration of Conformity (DoC), and valid certificate, ensuring transparency for both consumers and customs officials.
Chile is also implementing QR code requirements to streamline technical specifications and safety standards verification. External packaging for all short-range devices, like WiFi and Bluetooth, must feature a unique QR code, linking to a dedicated, live technical repository of test reports and specifications.
Indonesia is now integrating digital markings to help manage its complex import requirements, including the verification of mandatory standards for consumer electronics and household equipment. It is increasingly integrating digital markings into its SNI (Indonesian National Standard) verification process to manage the high volume of imported consumer electronics.
China remains a rigorous labelling environment and has an increasing focus on digital integration to track product provenance and compliance. It is currently transforming its CCC Mark system into a digital-first model to combat counterfeiting. Also, a new traceability QR code is mandatory for pilot categories, including power banks, electric bicycles and gas appliances. The code links directly to the Certification and Accreditation Administration database to verify product authenticity.
The European Union’s Ecodesign for Sustainable Products Regulation is the most ambitious digital labelling initiative globally. Starting in 2027, priority product groups (textiles, steel and eventually electronics) will require a Digital Product Passport (DPP) accessible via a data carrier, which is likely to be a QR code. While the Argentinian model focuses on safety certificates, the DPP covers lifecycle data: material composition, repairability and carbon footprint. While full DPP obligations for electronics are expected closer to 2030, horizontal eco-design requirements, including repairability and spare parts availability data, are expected to apply much sooner and will require the same underlying data infrastructure.
India has already made QR codes mandatory for self-ballasted LED lamps and for batteries, allowing regulators to track compliance throughout the supply chain.
While the USA’s E-LABEL Act allows devices with screens to display FCC marks digitally, the Food and Drug Administration introduced 2025 rules for medical device cybersecurity. This mandates that manufacturers document and disclose all software components within a device, providing digital access to software bill of materials and communication interface data.
As labels are the physical link to a product's Declaration of Conformity and technical files, the execution of a label is as critical as the information it contains, and the manufacturer’s label must include mandatory identification data.
Compliance markings must last the expected product lifetime under normal conditions of use, so require testing against environmental factors and cleaning processes. Both CE marks and UKCA marks must be at least 5mm in height, maintaining the dimensions of the original template. Contrasting colours are recommended to ensure legibility. If the product size permits, the marking must be applied directly to it. Aesthetic considerations do not justify the omission of a marking and placement on the packaging. Omission is only permitted if the product is physically too small to accommodate it.
Product identification should also be managed carefully throughout the product lifecycle. TÜV SÜD’s Global Market Access experts have seen manufacturers unintentionally create certification challenges through inconsistent model-numbering strategies.
Some manufacturers change model numbers whenever a software version is updated, even though the model number should normally identify the underlying product or hardware rather than a particular software release. Creating a new model number may require a certificate amendment, additional assessment or separate certification, depending on the market, certification scheme and nature of the change.
Manufacturers have also used generic wildcard suffixes, such as “X3V2-XXXX”, to cover multiple product variants. Model identifiers should instead distinguish variants clearly and consistently. Where products have the same RF characteristics and differ only cosmetically, it may be possible to use an overarching product-family model structure and distinguish individual products through part numbers, provided the approach is accepted under the relevant certification scheme and the variants are properly assessed and documented.
Similarly, introducing a new model number or suffix for a minor cosmetic change can create unnecessary certification work. For example, changing “GMA-500” to “GMA-501” solely because the product is a different colour could make functionally identical products appear to be separate hardware variants. Manufacturers should therefore agree their model and variant structure early and apply it consistently across product labels, test reports, certificates and technical documentation.
Digital labelling uses a self-adhesive product sticker or tag produced directly from a computerised design file, without physical printing plates. It can also use a QR code or another data carrier to connect the product to digital compliance information, such as safety credentials, certification status, declarations of conformity, test reports and technical specifications.
Digital labelling offers a range of compliance, operational and cost benefits for manufacturers:
While certain sectors such as medical devices, marine and construction operate under sector-specific timelines, the fundamentals of traceability and durability remain universal. As global requirements shift towards digital integration, early adoption of QR-based labelling is becoming a prerequisite.
With QR codes in Chile, Argentina and China requiring links to live documents, manufacturers should centralise compliance hosting with technical files hosted on stable, secure and permanent URLs. They should also establish a process for monitoring and updating hosted compliance documents throughout the product lifecycle, as a non-resolving or out-of-date link is treated the same as a missing mark at the border.
It is also vital to integrate the label within the product design early and not treat it as a sticker to be added later. For example, in China the QR code must be inseparable from the CCC Mark, often requiring changes to product moulds and printing plates. Likewise, although the EU’s full DPP for electronics is expected closer to 2030, the horizontal requirements for repairability data are expected much sooner, so it is advisable to start tackling this now to future-proof EU market access.
TÜV SÜD helps manufacturers stay ahead of changing digital labelling, QR code compliance and global market access (GMA) requirements. Our regulatory experts provide practical guidance on country-specific labelling regulations, helping you understand and implement requirements across global markets before they become barriers to entry.
We offer end-to-end labelling and compliance support, from reviewing existing labelling processes and technical documentation to helping you transition from traditional product markings to QR code-based digital compliance systems. Our team can assess your current approach, identify gaps and support the implementation of secure, accessible compliance information that meets evolving regulatory expectations.
By working with TÜV SÜD, you can reduce the risk of product launch delays, customs hold-ups and market access issues caused by missing, outdated or inaccessible digital compliance information. We help you build robust labelling and traceability processes that support smooth international product launches and ongoing compliance throughout the product lifecycle.
Our GMA team can support you in reviewing your current labelling processes and preparing for the transition to digital compliance across global markets.
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