Choose the carrier on the correct legal basis
Under ESPR, product-specific rules determine the carrier and placement. For battery passports, Article 77(3) expressly points to the QR code required by Article 13(6). A Data Matrix symbol is therefore not an interchangeable substitute merely because both are two-dimensional codes.
Record the applicable product rule and the person who approved the carrier choice. Keep other packaging codes identifiable. A logistics code, an energy-label link and a passport link may serve different purposes even when they sit on the same package.
Source: Regulation (EU) 2024/1781: Articles 9–11 and 41Source: Regulation (EU) 2023/1542: Articles 13 and 77
Approve the destination before generating artwork
Our engineering recommendation is to encode a durable product-record address, rather than an expiring download link or a temporary preview. Keep the object identifier separate from the current document location so a storage migration does not require relabelling products already in circulation.
Review the exact encoded string, not only the page shown after redirects. Check the hostname, identifier and record level. Remove accidental test-environment destinations and unnecessary parameters. Decide who maintains the address if the original project team, supplier or hosting arrangement changes.
Calculate a printable size instead of choosing arbitrary millimetres
DENSO describes a clear margin of four QR modules on every side and recommends at least four printer dots per module for stable operation. These are QR design and printing guidance, not a universal legal minimum label width.
An illustrative calculation: assume the encoder produces a symbol 33 modules across. Adding both margins gives 41 modules. At 300 dpi and four dots per module, the overall width is approximately 13.89 mm: 41 × 4 × 25.4 ÷ 300. This is a geometry example, not an acceptance threshold or proof that a particular scanner will read the label.
Recalculate after changing the payload or error-correction setting. Check the dimensions in the final print workflow; an application that scales a page to fit can change the actual module size.
Source: DENSO WAVE: determining QR code area and marginSource: DENSO WAVE: module size and printer resolution
Test the label on the real product
Choose samples from the intended printer, stock and attachment method. Test on the actual surface, including curvature, reflective material or nearby print. A flat paper proof is useful but does not reproduce a label wrapped around a small component.
Define relevant handling conditions with the product team. For example, inspect whether abrasion, moisture, cleaning or unpacking obscures the code or separates it from the product. These are suggested pilot scenarios, not invented standard limits. Select severity and sample coverage according to the actual use and applicable requirements.
Source: DENSO WAVE: module size and printer resolutionSource: Regulation (EU) 2024/1781: Articles 9–11 and 41
Separate decoding, identity and access checks
Use an acceptance record that can be repeated after a print supplier or material changes. A scan is only the beginning: it must decode the approved payload, reach the intended record and show information appropriate to the user. Test a wrong or unknown identifier too, so failure cannot silently open an unrelated product.
Keep the printed sample, production settings and observations together. Assign a reviewer who can stop release when the physical result differs from the approved artwork.
- Compare the decoded string with the approved payload exactly.
- Scan representative devices under documented conditions; record failures as well as successes.
- Check public access separately from authorised service access.
- Recheck the record after a revision without changing the product identity.
Use software checks as one part of the release
Passvanta can generate carriers from a resolver URL and calculate print geometry from target width and printer resolution. A software decode check supports review of the generated file. It does not replace verification of the printed carrier or establish conformity with every standard clause.
Start with one prepared product, verify the approved passport record and export a pilot label. Complete the physical review before ordering a large print run. Preserve the release decision and repeat affected checks when the carrier, printer, substrate or destination changes.