Your 2D Barcode Readiness Checklist for Sunrise 2027
I pulled up the GS1 placement specifications on my second monitor, then walked out to our carton line to measure the gap between our current UPC and the spot where a DataMatrix could fit. Thirty-eight millimeters on the flagship SKU. Forty-six on the travel size. Both within tolerance, but only if we shave the marketing QR code that the brand team added last year. That is the kind of real-estate arithmetic that every quality and compliance function will be running repeatedly between now and 2027.
For context, I manage quality assurance for a beauty and personal-care company with roughly 200 employees. Seven years on the packaging quality side, spanning barcode readability, print verification, and artwork approval across Amazon, mass retail, and our direct-to-consumer channel. When I attended the GS1 and Amazon Transparency sessions at PACK EXPO East in Philadelphia this month, the presentations confirmed something I had been suspecting since late last year: the shift to 2D barcodes at point of sale is no longer theoretical, and the quality implications are tangible.
What alarmed me most was a figure shared by Clay Ryan, head of worldwide business development at Amazon Transparency. Amazon's informal polling of brand partners suggests that fewer than 20% are actively planning for Sunrise 2027 or mapping out how serialization fits into upcoming packaging refreshes. If your company redesigns packaging on a three-to-five-year cycle, the window for consolidating that work into a single update is narrowing fast. Ryan described a large CPG that had been planning a 2027 packaging refresh without any awareness of the Sunrise 2027 requirements. Had they proceeded, they would have needed to redesign again almost immediately -- "essentially paying twice for the same work," as he put it. That scenario is exactly what keeps me auditing specs at ten o'clock at night.
Below is the readiness checklist I built for our own team after the sessions. I have organized it around the steps that matter most from a quality, compliance, and data-integrity perspective.
Step 1: Confirm What Sunrise 2027 Actually Requires
Sunrise 2027 in the U.S. -- and Ambition 2027 globally -- establishes a milestone for retail point-of-sale systems to be capable of scanning a 2D barcode and extracting at least the GTIN. This is a readiness date, not a mandate to strip existing barcodes off your packaging.
Andrew Morehead, director of community engagement at GS1 US, was unambiguous: "The 1D barcode is not going anywhere. There's no sunset of the UPC or EAN barcode." That matters for quality teams because it means we are entering a dual-marking transition period, not a sudden cutover. Your existing linear barcodes stay. A compliant 2D symbol gets added alongside them.
The Sunrise 2027 implementation guide, developed with input from more than 300 companies across retail, brand, and technical sectors, outlines packaging, data, and system-readiness considerations for manufacturers and retailers alike. I recommend pulling it into your QMS documentation library as a reference standard.
Step 2: Select Your Compliant 2D Symbol Format
GS1 outlined three compliant 2D options for brands:
- GS1 DataMatrix
- QR codes with GS1 Digital Link
- DataMatrix with Digital Link functionality
Each can encode the GTIN at minimum. Additional data elements -- lot, batch, expiry date, serial number -- can also be embedded. When I tested GS1 DataMatrix on our verification station, the grade came back consistently at a C or above on matte cartonboard, which meets most retailer thresholds. QR codes with Digital Link performed well on glossy substrates but needed tighter contrast ratios on our kraft secondary packaging. Your mileage will depend on substrate, print method, and line speed, so qualification testing is non-negotiable.
Step 3: Apply the 50mm Placement Rule
This was the most operationally specific guidance from the sessions. Steven Keddie, senior director at GS1 Global Office, explained that the 2D symbol should be within 50 millimeters of the existing linear barcode. The reason is practical: cashiers at high-speed checkout already know where the 1D barcode is, and scanners need to pick up the 2D code without a separate search motion.
Keddie also noted that modern scanners read 2D barcodes faster than 1D. From a quality standpoint, the 50mm rule forces you to evaluate artwork layout, symbol sizing, and quiet-zone clearances together. On our side, I created a placement template overlay for our packaging engineers so every new artwork revision gets checked against this constraint before going to print approval.
Step 4: Assess Small-Format Packaging Separately
Not every SKU can carry dual marks. Keddie acknowledged that smaller products like stick packs will likely carry only the 1D linear barcode. For our sample sachets, single-serve packets, and narrow blister formats in the OTC part of our line, dual-marking simply does not fit without sacrificing quiet zones or legibility.
My recommendation: flag every SKU below a certain panel-area threshold and classify it as 1D-only for the transition period. Revisit once retailers signal readiness to accept 2D as the sole identifier. Keddie's advice here was sensible: "Start small. Start with one product, work your way through it, understand how it gets there."
Step 5: Audit Your Current On-Pack Code Inventory
Clay Ryan made a point that resonated with anyone who has ever tried to approve a back-panel layout. Many brands currently carry three to four separate codes on pack: a UPC, a marketing QR code, an authentication code, and lot or batch data. Each one consumes space. His proposal is a single GS1-compliant 2D barcode incorporating GTIN, serialization, and Digital Link functionality. "This single 2D barcode does everything," Ryan said. "It returns precious real estate for packaging artwork to designers."
From a quality perspective, fewer codes means fewer verification points, fewer potential scan failures, and a cleaner layout that reduces the chance of artwork errors during revision cycles. I started cataloging every code on every active SKU so we can build a consolidation roadmap.
Step 6: Evaluate Serialization -- Optional but Strategic
Serialization itself remains optional under Sunrise 2027. Ryan was clear: "Serialization itself will be optional... however, we think that the benefits of serialization will be very strong for both brands and retailers." For a beauty brand that sells through Amazon, the relevance is immediate. Amazon Transparency now serves 88,000 brands worldwide, providing unit-level serialization as a product authentication service. For products shipped through Fulfillment by Amazon, every serialized unit is scanned before shipment.
The benefits extend beyond counterfeiting. Ryan described serialization as infrastructure for order-defect prevention, diversion detection, and supply-chain visibility. In a recall scenario, traditional 1D identification often forces broad recalls across entire production runs. With serialization, "you can target your recall with surgical precision." For our brand, which manages allergen-sensitive formulations, that kind of lot-level and unit-level targeting could be the difference between recalling 500 units and recalling 50,000.
Brands already running proprietary serialization systems can integrate with Transparency without replacing existing infrastructure, which means prior investment is preserved, not discarded.
Step 7: Map Sector-Specific Compliance Drivers
The sessions made clear that different industries are reaching the same 2D destination from different starting points.
- Fresh food: Retailers are already leveraging expiry data encoded in 2D codes. Keddie described programs where stores "look at the expiry date, they can do automatic price down" to reduce shrink on produce, meat, and prepared foods.
- Apparel and general merchandise: European Digital Product Passport requirements are pushing QR codes with Digital Link onto garments and footwear, linking physical product instances to digital sustainability records.
- Healthcare and OTC: Pharmaceutical and medical-device companies have long used GS1 DataMatrix for UDI and traceability. As OTC brands sell through both mass retail and e-commerce, those 2D capabilities intersect directly with Sunrise 2027 POS expectations.
- Consumer electronics: Brands already serializing for diversion control are assessing how to align proprietary systems with GS1 standards.
On the regulatory side, Keddie warned that brands subject to the Digital Product Passport who do not begin testing 2D printing now are "going to be in big trouble." For U.S.-focused operations, FSMA 204 traceability requirements add another compliance layer where serialized 2D data could reduce audit burden and enable faster response to food-safety events.
Step 8: Align Your Packaging Refresh Cycle with 2027
This is the planning step where quality, procurement, brand, and IT all need to sit in the same room. If your next packaging refresh falls between now and 2028, you have one chance to incorporate 2D symbology, updated artwork templates, and serialization infrastructure in a single cycle. If you miss it, you face exactly the double-redesign scenario Ryan described.
For quality teams specifically, aligning means updating incoming-material specs for preprinted substrates, revising print-quality acceptance criteria to include 2D verification grades, and ensuring that any new coding or marking equipment on the line can handle variable data at the required resolution.
Step 9: Evaluate Coding and Marking Technology
At PACK EXPO East, coding and marking exhibitors including Domino, Markem-Imaje, Matthews Marking Systems, and Videojet were demonstrating 2D-capable printing systems, variable-data solutions, and software designed for GS1 Sunrise 2027 and serialization. Inkjet, laser, thermal transfer, and print-and-apply technologies were all represented.
When I walked the floor, I focused on print resolution at production speed, because a DataMatrix that grades well on a static sample but degrades at 120 meters per minute is a quality risk, not a solution. I collected samples from four vendors and plan to run them through our verification station under production-equivalent conditions. I would advise any quality manager to do the same rather than relying solely on vendor spec sheets.
Step 10: Build Your Internal Readiness Timeline
Based on everything presented at PACK EXPO East, here is the sequence I am recommending to our leadership:
- Complete the on-pack code audit across all active SKUs (Q2 2026).
- Run qualification trials for at least two compliant 2D symbol formats on our primary substrates (Q2-Q3 2026).
- Finalize the artwork template incorporating the 50mm placement rule and dual-marking layout (Q3 2026).
- Evaluate serialization integration with Amazon Transparency for our top 20 SKUs by revenue (Q3-Q4 2026).
- Update QC incoming-inspection criteria and line-verification SOPs for 2D symbology (Q4 2026).
- Coordinate with our converter and contract packager for production-scale validation (Q1 2027).
Morehead and Keddie from GS1 emphasized that Sunrise 2027 is a retail-readiness milestone, not a cliff edge. But readiness on the retail side means brands need to have compliant symbols on pack when those scanners go live. From where I stand on the quality side, the specifications are clear, the technology is available, and the implementation guide built by those 300-plus companies provides a solid reference. The only variable left is whether we execute in time -- and with fewer than one in five brands actively planning, the ones who start now will carry a measurable advantage into 2027 and beyond.