The United Kingdom's Department for Business and Trade and Office for Product Safety and Standards published a consultation on a new product safety framework on 31 March 2026. Responses closed on 23 June. Proposal A12 describes an ambition for product information to become “digital by default”. It is a proposal, not a general permission currently in force to remove physical labels or warnings.
The proposal separates information by function
The practical question is not whether a product has a QR code. It is which information the buyer, user and authority need, and where each item must be available. Under A12, a serial number, batch number or other product identifier would still be supplied physically on the product or its packaging, or accompany the product where placing it there is not reasonable. A producer's name and contact details could be provided physically or digitally. Safety information, instructions and warnings could also be supplied through either channel under the proposed general framework.
That flexibility has a significant limit. Sector legislation or a standard followed for a product may require a warning on the product or packaging. The specific requirement would take priority. A business cannot infer from a broad consultation that an existing physical warning may be moved to a web page. The identifier also has a different role from an instruction: it links a physical item to its traceable batch, while the instruction must reach the user before the risky use occurs.
A digital label still has a physical entry point
The consultation proposes that a digital carrier, such as a QR code, should appear on the product or packaging. Its accompanying text should tell users what information it opens. If safety information is supplied digitally, users should be told to read it before using the product. The government also considers continued access over the expected life of the product, including after repair or refurbishment, and a free physical copy of safety information on request.
Those details matter operationally. Uploading a document once does not ensure that a link survives a packaging revision, that the document matches the batch in the customer's hands, or that a consumer with limited digital access can read an essential warning. A sensible preparation step is to map each field to its source, the product version, the intended market, the physical or digital location and the person responsible for updates. This is preparation advice rather than a statement of a new legal duty.
Consider one product sold with a QR code on its carton. It would be a mistake to put its batch identifier, the producer's contact details and every warning into a single “digital label” bucket. A12 would still treat the identifier as physical information. It would offer a possible physical or digital route for the contact details. For a warning, the company would first have to check whether sector legislation or a standard it follows requires that warning on the product or packaging. This is a way to read the proposal, not a conclusion that any particular label may be removed under current law.
There is also a version-control problem. If an older carton continues to open a page written for a revised product, the link works technically but may show the wrong safety instructions for the item in the user's hands. A12 proposes that digital information remain accessible for the expected product lifetime, including after repair or refurbishment, and that a free physical copy of safety information be available on request. A business can prepare by testing links on old packaging, tying each page to the relevant product version and assigning responsibility for correcting broken or mismatched pages. Those steps are prudent preparation; they are not new duties already in force under A12.
Great Britain and Northern Ireland require separate checks
The consultation expressly notes that products sold in Northern Ireland are affected by the EU General Product Safety Regulation and would need physical labelling. A single internal “UK” column can therefore conceal a material market distinction. Companies selling the same SKU in Great Britain and Northern Ireland should check the rules applicable to each route, alongside any product-specific requirements.
The sales page is a separate question from the label on the product. A12 addresses information on or with the product; Proposal A13 in the same consultation addresses safety information presented to consumers before an online purchase. Putting a warning on an online listing does not itself resolve a physical-label requirement. Conversely, a QR code on packaging does not establish that a shopper had the information needed at the online decision point. Each surface needs its own current-law check before the business treats a proposed reform as permission to redesign it.
The best reading of A12 is a potential direction for reform, subject to the government's response and later legislation. For a label decision today, start with the law and standards currently applicable to that product and sales destination. Then use the consultation to prepare a maintainable information system, without treating its proposed digital flexibility as already operative.
Primary source: DBT/OPSS, The UK’s new product safety framework, Proposal A12. Checked 2 October 2026.
