Which brands need 2D barcodes first

Updated August 2026

Brands face different timelines based on their retailers, product category, traceability needs, and artwork schedule. Use those facts to decide which SKUs move first.

Move when the operating case is clear

• Fresh and short-shelf-life food. Expiry and lot data in the code drives markdown automation and waste reduction. That operational case does not depend on the Sunrise 2027 target.
• Brands whose retailers have already published 2D requirements. A retailer's supplier requirement is enforceable in a way an industry target is not.

Prepare the records before choosing a carrier

• Foods covered by FSMA 204. The rule requires traceability records for covered foods; it does not require a 2D barcode. FDA says Congress directed it not to enforce the rule before July 20, 2028. Settle the lot-code and record-retrieval workflow before deciding what to encode.
• Product groups prioritised under the EU ESPR working plan. Textiles, furniture, tyres, iron and steel, and aluminium are among the priorities. A working-plan priority is not yet a product obligation; monitor the applicable delegated act before making a compliance claim.

Plan with the next artwork cycle

• Shelf-stable grocery and household goods. Real pressure, long runway. Fold the change into your next scheduled artwork revision.
• Health and beauty. Consumer interest in ingredient transparency makes the consumer-page side of this worth doing well rather than fast.

Watch and wait

• Products that never cross a retail POS: food service, B2B industrial supply, and direct-to-consumer products. The POS argument does not apply. Traceability may still, on its own merits.
• Very small or awkward packages. Where the minimum symbol size does not fit, wait for guidance rather than printing something that will not scan.

A useful first check for every category

Validate the GTIN data before choosing artwork or resolver options. The same catalog problems affect every path described above, and they can be corrected without changing packaging.

Primary sources: FDA Food Traceability Rule overview and the EU 2025–2030 ESPR working plan.