2D barcode declarations: what a scan cannot replace

The answer first: the Rules do not let declarations move

Rule 6(4A) of the Legal Metrology (Packaged Commodities) Rules, 2011 is the provision that mentions codes at all. It permits a manufacturer, packer or importer to put a barcode, a GTIN or a QR code on the package in addition to the mandatory declarations. That is a permission to add, not a permission to substitute. There is no general provision in the Rules letting a mandatory declaration live behind a scan instead of being printed.

So on a food, cosmetic, apparel or general FMCG pack sold in India, every mandatory declaration stays printed and the QR code sits alongside it. The declaration set itself, and the duty to repeat it on the listing, belong to legal metrology labelling. The answer to the newer question is simply that a 2D code does not shrink that set by one line.

The one real carve-out, and it is electronics only

There is an exception. It is narrow, it is older than most people think, and it is now open ended. The Legal Metrology (Packaged Commodities) (Second Amendment) Rules, 2022, notified on 14 July 2022, inserted provisos to rule 6 for electronic products manufactured, packed or imported after 15 July 2022, originally for one year only. G.S.R. 456(E) dated 23 June 2023 then substituted those provisos and dropped the one-year limit, so the facility now carries no stated end date.

For an electronic product, these may be given through a QR code where they are not printed on the pack:

• The address and other related information of the manufacturer, packer or importer.
• The common or generic name of the commodity, and for a multi-product pack, the name and number or quantity of each product.
• The size and dimension of the commodity.
• Consumer care information beyond the telephone number and email address.

These must still be printed: the name of the manufacturer, packer or importer, and the telephone number and email address. The pack must also instruct the consumer to scan the code for the rest. And the amendments never touched net quantity, retail sale price, or the month and year of manufacture, packing or import, so those stay on the pack for every category, electronics included.

Two traps. First, this reaches electronic products, and we found no equivalent proviso for any other category. Second, the scan instruction is part of the condition, so an electronics brand that moves the address behind a code and forgets the on-pack prompt has not used the facility, it has dropped a declaration.

Which Indian rules require a code, and which are only draft

The three usually cited together are not the same kind of thing, so separate and date them.

• Pharmaceuticals, real and in force. The Drugs (Eighth Amendment) Rules, 2022, notified by G.S.R. 823(E) dated 17 November 2022, inserted Schedule H2 and new sub-rules in rule 96 of the Drugs Rules, 1945. Listed brands must carry a barcode or QR code on the primary label, or on the secondary label where the primary lacks space, for batches manufactured on or after 1 August 2023. Note the wording: barcode or QR code. It is a machine-readable authentication duty, not specifically a 2D mandate.
• Jewellery, real but not a 2D code. The BIS hallmarking scheme requires a six-digit alphanumeric Hallmark Unique Identification number, laser marked on the article alongside the BIS mark and the purity mark. It became part of the mark for gold from 1 July 2021, and sale of gold jewellery without it was barred after 31 March 2023. BIS extended HUID to hallmarked silver with effect from 1 September 2025. A HUID is a code a consumer types into the BIS Care app. It is neither a QR code nor a barcode, so do not file it under 2D.
• Food, not notified. FSSAI issued an advisory dated 12 October 2023 encouraging food businesses to add QR codes so label information is accessible to visually impaired consumers, and that advisory itself says a QR code does not replace or negate the mandatory information on the label. A Lok Sabha answer of 8 December 2023 described the use of QR codes for accessibility as voluntary. GS1 India’s own industry forum deck of 7 August 2026 still lists FSSAI QR labelling as in draft. We found no notified FSSAI regulation requiring a QR code on a general packaged food pack.

What a 2D code buys you with no rule change at all

This is the part worth acting on, because none of it waits on a regulator.

Batch and expiry at the till. GS1 US lists the retail uses of Digital Link as flagging recalled, expired or counterfeit product in the warehouse and at the point of sale, and automatically discounting product near or past expiry. GS1 India’s pilot at Reliance Retail encodes product identification plus batch number, expiry date and MRP, which is the same idea inside an Indian store.

Recall precision. If the batch sits in the code and is captured at despatch, the scope of a recall becomes a query rather than a reconstruction. The records side of that, one step back and one step forward, belongs to batch code traceability and does not change because the symbol got denser.

Diversion tracing, with a caveat. A GTIN plus a batch tells you which consignment a unit came from, which is usually enough to find a leaking distributor. Tracing an individual unit needs a serial in the code, which is a materially bigger and costlier build. Amazon says plainly that unit-level serialisation is not required for the 2027 point-of-sale transition.

Where this touches your FSSAI label and your batch code

Keep the two layers separate in your head. The printed panel is a legal obligation, the code is an operational asset, and encoding something does not discharge printing it. An FSSAI label still carries what the labelling regulations require, in the type sizes they require, whether or not the same data also sits in a QR code. A batch code still has to be printed legibly and captured at every handover, because a code nobody scans at despatch gives you nothing during an incident.

The practical sequence for an Indian brand is therefore boring and cheap. Leave the printed declarations alone. Put the GTIN, batch and expiry in the code. Make sure despatch actually scans it. Then, if a buyer asks for 2D at point of sale, you are already most of the way there.